oEPA
            United StatM
            Environmental Protection
            Agency
            Off ice of
            Pesticides and Toxic Substanc
            Washington DC 20460
            Pesticides
                                       April 1987
Guidance for the
Reregistration  of
Pesticide Products
Containing  EPN
as the Active Ingredient

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           GUIDANCE  FOR THE




RE REG I STRATI ON OF PESTICIDE PRODUCTS




              CONTAINING




                 EPN




      AS THE ACTIVE  INGREDIENT






     CAS  REGISTRY NO.  2104-64-5




     OPP SHAUGHNESSY NO.  041801






         EPA  CASE NUMBER 147









    ENVIRONMENTAL PROTECTION AGENCY




    OFFICE OF PESTICIDE  PROGRAMS




      WASHINGTON,  D.C.   20460

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                        TABLE OF CONTENTS


I.    Introduction 	    1

II.   Chemical(s) Covered by This Standard	    3

        A.  Description of Chemical	    3

        B.  Regulatory History	    3
            1. Cancellation of Uses in The Absence of a
                 Finite Tolerance	    3
            2. Classification of Certain Use Patterns as
                 Non-food Uses	    4
            3. Classified as Highly Toxic to Bees	    4
            4. Specific Reentry Period Designated	    4
            5. Certain Uses Classified for Restricted Use. .  .    4
            6. Retuttable Presumption Against Registration .  .    5
            7. Data Call In	10

        C.  Use Profile	11

III.   Agency Findings	13

        A.  Summary	13
            1.  Summary of Agency Conclusions	13
            2.  Summary of New Agency Position Based  on
                  Information and Assumptions Used in
                  the Current Assessment of Risk	16
            3.  Summary of Agency Position on Other Effects.  .  17

        B.  Health Risk Assessment	18
            1. Acute Toxicity	19
            2. Subchronic Toxicity 	  19
            3. Chronic Toxicity	21
            4. Oncogenicity	21
            5. Teratogenicity	  22
            6. Reproduction.	22
            7. Mitagenicity	*....  22
            8. Metabolism	23
            9. Neurotoxicity Recovery  Study in Hens	25
           10. Toxicological Issues Associated With
                 Delayed Neurotoxicity 	  26
           11. Risk Assessment for Delayed Neurotoxicity  ...   29
                 Dietary Risk Assessment	29
                 Non-dietary Risk Assessment (applicators  and
                     reentry)	33
        C.  Environmental Profile	35
            1. Ecological Effects	35
            2. Endangered Species	42
            3. Environmental Fate	  42

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                   TABLE OF CONTENTS (continued)

        D.   Tolerance Reassessment 	  43
            1. Residue Data	44
            2. Pesticide Monitoring Data	74
            3. Toxicological Data and Acceptable
                 Daily Intake	74
            4. Tolerance Reassessment Summary and
                 Current Tolerances.	76

IV.   Regulatory Position and Rationale	79

        A.   Regulatory Positions	.,	79

        B.   Criteria for Registration	84

        C.   Acceptable Ranges and Limits	84

        D.   Reguired Labeling  	  85

V.    Products Subject to This Standard	91

VI.   Reguirement for Submission of Generic Data	93

        A.   What are generic data?	93

        B.  Who must submit generic data?	93

        C.   What generic data must be submitted?  .......  94

        D.   How to  comply with DCI reguirements	94

        E.   Testing protocols, standards for donducting
              acceptable tests, guidance on evaluating
              and reporting data	97

        F.  Procedures  for reguesting a change  in protocol  .  .  97

        G.  Procedures  for reguesting extensions  of time ...  97

        H.  PR Notice 86-5 and any other reguirements
              referenced or included within this  notice. ...  98

        I.  Existing stocks provisions upon suspension or
            cancellation	98

VII.  Reguirement for Submission of Product-Specific Data   .  .  99

VIII. Requirement for Submission of Revised Labeling	100
                                  11

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                   TABLE OF CONTENTS (continued)

IX.    Instructions  for Submission	100
        A.   Manufacturing use products (sole active)	100

        B.   Manufacturing use products (multiple  active)  .  .  .101

        C.   End use products	 102

        D.   Intrastate products   	 103

        E.   Addresses	103
                               iii

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                           APPENDICE

I.  DATA APPENDICES

    Guide to Tables	104

    Table A	106

    Table B	138



II.  LABELING APPENDICES

     Summary of Label Requirements and table	142

     40 CFR 162.10 Labeling Requirements 	 152

     Physical/Chemical Hazards Labeling Statements  .... 161

     Storage Instructions	162

     Pesticide Disposal Instructions 	  ... 163

     Container Disposal Instructions 	 164


III.  USE INDEX APPENDIX	165


IV.  BIBLIOGRAPHY APPENDICES
     Guide to Bibliography	194

     Bibliography	196


V.  FORMS APPENDICES

FIFRA §3(c)(2)(B) Summary Sheet   (EPA  Form 8580-1)

Certification of Attempt to Enter into an Agreement with Other
Registrants  for Development of Data  (EPA Form 8580-6)

Product Specific Data Report  (End-Use  Products)

Formula tor's Exemption Statement
                                  IV

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                             -1-

                        I.   INTRODUCTION

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

     The Registration Standards program involves a thorough
review of the scientific data base underlying  a  pesticide's
registration.  The purpose  of the Agency's review  is to
reassess the potential hazards arising from the  currently
registered uses of the  pesticide; to determine the need  for
additional data on health and environmental effects;  and to
determine whether the pesticide meets  the  "no  unreasonable
adverse effects" criteria of FIFRA.  In its review EPA identifies

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

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

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

     The detailed scientific review, which is  not  contained
in this document, but is available upon request^,  focuses  on
the pesticide active ingredient.  The scientific review
primarily discusses the Agency's evaluation of  and conclusions
from available data in its files pertaining to the pesticide
active ingredient.   However, during the review of  these  data
the Agency is also looking for potential hazards that may  be
associated with the end use products that  contain  the active
ingredient.  The Agency will apply the provisions  of  this
Registration Standard to end use products  if necessary to
protect man and the environment.

     EPA's reassessment results in the development of  a
regulato.ry position, contained in this Registration  Standard,
•'•The scientific reviews may be obtained from the Information
 Services Section, Program Management and Support Division
 (TS-757C), EPA, 401 M St., SW, Washington, D.C.  20460.

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                             -2-

on the pesticide and each  of its registered uses.   See
Section IV - Regulatory Position and  Rationale.   Based on its
regulatory position, the Agency may prescribe  a  variety of
steps to be taken  by registrants to maintain  their registrations
in compliance with FIFRA.  These steps  may include:

     1.  Submission of data  in support  of  product registration;

     2.  Modification of product labels;

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

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

     5.  Modification of uses  or formulation  types;  or

     6.  Specification of  packaging limitations.

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

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

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

     Registrants are  reminded  that FIFRA sec.  6(a)(2)  requires
them to submit factual information concerning  possible unreason-
able  adverse effects  of a  pesticide at  any  time  that they
become  aware of  such information.  Registrants should  notify
the Agency of any  information, including interim or preliminary
results of studies, if those results  suggest  possible  adverse
effects on man or  the environment.  This requirement continues
as  long as the products are  registered  by  the  Agency.

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                             -3-

          II.  CHEMICAL COVERED BY THIS STANDARD

                 A.  Description of Chemical

     EPN is the accepted abbreviation for the  chemical  O-ethyl
O-p-nitrophenyl phenylphosphonothioate.  There is  no official
common name.  The basic manufacturer of EPN is Nissan Chemical
Works, Ltd. of Japan.  There are currently no  technical  EPN
products registered in the United States.^

     Some identifying codes and characteristics are:

     Chemical Class: non-halogenated, aromatic, phosphonothioate
                     organ ophosphorus compound.
     Empirical Formula:

     Molecular Weight:     323.3

     CAS Registry No.:     2104-64-5

     OPP Shaughnessy No.:  041801

     The pure compound occurs as a light-yellow crystalline
powder with an aromatic odor and the technical grade is a
red dish- ye How oily liquid.  EPN is only slightly soluble
in water and is miscible with benzene, toluene, xylene, acetone,
isopropyl alcohol, and methanol.  EPN has a melting point of
34.5°C, vapor pressure of 0.03 mmHg at 100°C and specific
gravity of 1.27 at 20°C.


                    B .  Regulatory History

     EPN was first introduced in 19.49 by E. I. du Pont de Nemours
and Company, Inc.  In 1950 E. I. du Pont de Nemours and Company,
Inc. obtained a patent for EPN  (Patent Number 2503390) and the
first registration and tolerances were issued for the chemical
in the same year.  During the ensuing years EPN has been
subjected to the following regulatory actions.

1 .  Cancellation of Uses in The Absence of a Finite Tolerance

     PR Notice 68-6 published on February 1, 1968, proposed the
cancellation of use of EPN on onions in the absence of a finite
tolerance or exemption.
  Active registrations for, technical EPN were formerly held by
  E. I. du Pont de Nemours,  Laroche Industries,  Inc., Marubeni
  America, J.  R. Simplot Company, and Velsicol Chemical Company.
  However, these registrants have requested voluntary cancellation
  of their registrations for technical EPN in lieu of developing
  the data required to support the continued registration of their
  products.

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                             -4-

2.  Classification of Certain Use Patterns as Non-food Uses

     PR Notice 68-8 published on April  24, 1968, classified
certain chemical use patterns as non-food uses, allowing
registration of products  for these  uses to continue  in the
absence of finite tolerances.  Use  of EPN as a special mosquito
larvicide was classified  as a non-food  use.

3.  Classified as Highly  Toxic to Bees

     PR Notice 68-19 published on November 29, 1968, classified
EPN and certain other pesticides as highly toxic to  bees and
required the label statement, "This product  is highly toxic  to
bees exposed to direct treatment or residues on crops.  Protective
information .may be obtained from your Cooperative Agricultural
Extension Service."

4.  Specific Reentry Period Designated

     On May 10, 1974, the Agency published in the Federal
Register (39 FR 16890) a  list of 9  pesticides designated for
a specific reentry period in 40 CFR 170.3 (b).  EPN was one of
those  9 pesticides.  Pesticide products containing EPN have  a
reentry time of at least  24 hours,  prior to  which workers must
wear protective clothing  in order to  be permitted to enter a
field  treated with EPN.

5.  Certain Uses Classified for Restricted Use

     On August 1, 1979, the Agency  published a proposed rule
in  the Federal Register which would amend  40 CFR 162.31 by
adding uses of active ingredients to  be classified for
restricted use under 40 CFR 162.30.  Under the proposed rule,
all EPN liquid and dry formulations greater  than 4%  and all
EPN granular formulations 2% and greater would be classified
for restricted use  (44 FR 45218).   This proposed rule was
based  on the risk criteria for determining a pesticide's use
classification, as provided in 40 CFR 162.11 (c)(2)  through  5,
which  require  that determinations concerning the use classifi-
cation of a pesticide must take into  account the pesticide's
existing toxicity category, the  level of  risk posed  to humans
and the environment, the  adequacy of  present labeling, and
other  hazard information.

     The Agency published the  final rule in  the Federal
Register on January  19,  1981, adding  certain uses of eight
active ingredients  (including EPN)  to the  list of uses which
the Agency has classified for restricted use (46 FR  5696).
The final  rule regarding  EPN classification  became effective
on June 10, 1981  (46 FR  29708), whereupon  all uses of EPN
liquid and  dry (granular and wettable powder) formulations
greater than 4% were classified  for restricted use.               !

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                             -5-

6.  Rebuttable Presumption Against Registration  (RPAR)

     On September 19, 1979, the Agency  issued  a  Notice  of
Rebuttable Presumption Against Registration3 of  Pesticide
Products Containing EPN (44 FR 54384).  The Agency based the
presumption against registration upon studies  showing that
EPN caused delayed neurotoxic effects in test animals,  and
was acutely toxic to aquatic organisms.  The Agency  also
identified five other possible adverse effects of EPN for
which insufficient information existed to  issue  a rebuttable
presumption.  Those effects were: (1) teratogenic effects;
(2) cholinergic effects; (3) disorders of  the  eye; (4)
possible mutagenic effects; and, (5) reductions  in populations
of nontarget organisms (honeybees).  The existence of a data
gap for oncogenic effects was also noted.  In  addition, the
Agency noted that, when used in combination with malathion,
dimethoate, or Systox, EPN had been observed to  potentiate
the acute toxicity of these chemicals, i.e., causes  the total
effect of the two chemicals to be greater than the sum  of the
two effects taken independently.

     The EPN laboratory animal (chicken) neurotoxicity  studies
which formed the basis for the Agency's Special  Review  (RPAR)
demonstrated that EPN caused many effects  characteristic of
organophosphate-type delayed neurotoxicity.  Some of these
characteristics are:  a delay of from 10 to 14 days  between  a
single effective dose and the appearance of clinical and
histopathological signs; the appearance of the delayed  effect
well after the recovery from the acute toxicity  of the  compound;
the appearance of abnormalities in gait which may proceed  to
complete paralysis and are generally irreversible; and, the
destruction of nerve axons in the spinal cord  and the subsequent
disappearance of the myelin sheath which surrounded  the lost
axons.  However, due to inconsistencies in those studies the
Agency at that time concluded it could not use those studies to
establish a NOEL for EPN delayed neurotoxic effects.   Rather,
the Agency used a human study, in which a NOEL of 0.1 milligrams
per kilogram (mg/kg)  per day was established for EPN-induced
3The Agency created the Rebuttable Presumption Against
 Registration (RPAR) process to facilitate the identification
 of pesticide products (or uses thereof) which may not satisfy
 the statutory standard for registration, and to provide an
 informal procedure through which to gather and evaluate
 information about the risks and benefits of these products
 and uses.  Subsequently, on November 27, 1985, the Agency
 published revised, final regulations (40 CFR Part 154) in which
 the term RPAR was changed to Special Review.  A Special Review
 arises if a pesticide meets or exceeds any of the risk criteria
 set forth in the regulations.

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                             -6-

depression of plasma and red blood cell  (RBC)  cholinesterase
levels as the most sensitive indicator for  human  toxicity.   On
that basis the Agency calculated dietary and applicator  risks
posed by the continued uses of EPN.   (However,  as explained
below in Section III. A. 2., III. B.  2., and III.  B.  9.,
data on histopathological  changes  in  the spinal cord  are
more appropriate for setting a NOEL for human  risk assessment
purposes.)

     The maximum dietary burden  if EPN were used  on  all  crops
for which it was registered was  calculated  to  be  0.016 mg/kg
of body weight  (bw) per day for a 60  kg person.   The  maximum
dietary burden  assumed that EPN  residues existed  on  each
commodity at the full tolerance  level.

     Based on tolerances for cotton,  corn,  and soybeans,  three
crops comprising the bulk  of EPN useage, the sum  of the  dietary
burdens for  these crops was calculated to be 0.00036  mg/kg/day
for a 60 kg individual.  This calculation factored in the
percent of the  crop  treated.  Based on this exposure  estimate
and the oral NOEL of 0.1 mg/kg/day  for blood cholinesterase
inhibition in humans, an acceptable Margin  of  Safety  (MOS)
of 277 existed.  The Agency's Position Document 4 stated that
an acceptable MOS for cholinesterase  inhibition was 10 and
for delayed  neurotoxicity  was 100.

     The Agency also calculated  MOSs  for all applicator
groups, based on a human NOEL of 0.1  mg/kg  per day for EPN
cholinesterase  inhibition, using a worst case  and a more
realistic case  approach.

     1.  If  protective clothing  and a respirator  are  worn,
         applicator  exposure should be limited to the dermal
         route.  Using the worst case of 100%  dermal  absorption,
         and based on a NOEL of  0.1 mg/kg per  day, MOSs
         were calculated as follows:

              pilots - 38           loaders  -  4
              flaggers - 1        ground applicators -  9

         In  using the worst case approach,  MDSs for most
         applicator  groups were  considered  unacceptable.

     2.  Another approach  was used  to reflect  a more  realistic
         risk to applicators from the use of EPN. In this
         approach the Agency, using acute  toxicity data,
         estimated a dermal absorption rate for EPN  to be
         approximately 31%.  Using  the 31%  dermal absorption
         value, the  following margins of safety ware  calculated:

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                             -7-

         pilots - 125         loaders - 13
         flaggers -  3         ground applicators  -  30

         Using the 31% absorption value, adequate MOSs  were
         considered  to exist for all applicator groups  except
         flaggers with regard to cholinesterase inhibition,
         but MOSs for the delayed neurotoxic  effect were
         below the accepted level except as to pilots.

     The Agency received a number of comments from registrants
and others regarding the risks and benefits of EPN in response
to the September 19, 1979 RPAR Notice.  In evaluating those
comments the Agency reevaluated EPN's chemistry, environmental
activity and movement, toxicity, effects upon wildlife  popula-
tions, and the exposure of humans and animals to  EPN.   The
Agency also evaluated the benefits of EPN use and the effects
of cancellation upon the agricultural economy.

     The Agency's reevaluation confirmed that EPN produces
delayed neurotoxicity in chickens but indicated that, although
subtle histological  effects were observed in  a well-conducted
test at 0.1 mg/kg per day, the toxicological significance of
these effects could not be determined without additional
study-  The Agency's reevaluation also confirmed  that EPN is
acutely toxic to honeybees, causing reductions in local and
regional populations of these nontarget organisms; and  is
acutely toxic to aquatic organisms (from the mosquito larvicide
use only).  The Agency's examination of use patterns  in effect
at that time and the potential for exposure indicated that  an
ample MOS existed for human dietary exposure and  for applicators,
with the exception of human flaggers.  With regard to honeybees,
the Agency determined that sufficient residues remain two to
three days after application to present an acute hazard to
bees.  However, the Agency determined that this acute toxicity
could be sufficiently mitigated with the use of appropriate
labeling.  Following this reevaluation of the risks and
benefits of EPN, the Agency concluded the RPAR for EPN  with
the issuance of a Decision Document in June 1983 and the
publication of its final notice of determination concluding
the RPAR for EPN in  the Federal Register on August 31,  1983
(48 FR 39494).  The Agency's final regulatory decision on EPN
at the conclusion of the Special Review (RPAR) is summarized
in Table 1 below.

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                                        -8-

Table 1 - Sumnary of EPA's Final Regulatory Decision Concluding the RIftR for EPN
      Use site
                Final decision
Mosquito Larvicide use

All other uses
Cancel.

Cancel, unless the following nodif ications are made
to the terms and conditions of registration:

Human flaggsrs prohibited unless in totally enclosed
vehicles.

Standardize label requirements for protective clothing,
goggles, and respirators, the phrase "protective
clothing required" to appear preminently in bold type
as follows:

    PROTECTIVE CLOTHING REQUIRED; Wear clean
    protective clothing, goggles, and respirators
    approved by NIOSH or the American National
    Standards Institute when applying or handling,
    or when reentering fields within [at least 24]
    hours of treatment.  The following protective
    clothing nust be worn: lightweight unlined
    natural rubber gloves at least mid-forearm in
    length; a wide brimmed waterproof hat or water-
    proof hood; a protective suit or coveralls of a
    non-permeable, non-cloth material covering the
    body from arkles to wrists; lightweight unlined
    natural rubber boots at least mid-calf in length;
    full-face respirators are reconrte nded; half-face
    respirators and goggles are required.

The following statement must appear in the "Use
Directions" section cf the label:

    "Do  not apply this product when weather conditions
     favor drift from treated area."

The following statement must appear in the
"Environmental Hazards" section of the label for
Vfettable Powder (WP) and Emulsifiable Concentrate (EC)
formulations:

    "This product is highly toxic to bees exposed to
     direct treatment or residues on blooming crops or
     weeds.  Do not apply this product or allow it to
     drift to blooming crops or weeds if bees are
     visiting the treatment area."
 (Table 1 continued on next page)

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                                        -9-
Table 1 - Summary of EPA's Final Regulatory Decision Concluding the RB^R for EPN
           (continued)
      Use site
                Final decision
WP and EC formulations
for use on Cotton
WP and EC formulations
for use on Field Corn
and/or Sweet Corn
WP and EC formulations
for use on Stone Fruitsf
Pome Fruits, and Citrus
All Food Uses
Areas for Further
Consideration
 In addition to  the  requirements for "All Uses", the
 following statement must  appear in the "Use Directions"
 section of  the  label:

     "Do not apply to blooming cotton if bees are
      visiting the treatment area."

 In addition to  the  requirements for "All Uses", the
 following statement must  appear in the "Use Directions"
 section of  the  label:

     "Do not apply to corn daring the pollen-shed
      period if  bees are visiting the treatment areas."

 In addition to  the  requirements for "All Uses", the
 following statement must  appear in the "Use Directions"
 section of  the  label:

     "Do not apply vhen trees or a substantial number
      of  veeds in the orchard/grove are in bloon."

 Reassess tolerances.  Data necessary to reassess EPN
 tolerances  will be  required in the Agency's Registra-
 tion Standard Review Process.

 The Agency  identified the following areas in which
 data vrere required:

 Teratogenic  effects.  Teratogenic studies in rats and
                      rabbits are needed.
                         Oncogenic  effects.


                         Delayed  neurotoxic effects.
                      Studies on the oncogenic potential
                      of EPN in rats and nice are needed.

                             A study to explore the
                             nechanisoi of "recovery"
                             from a mild case of
                             EPN-induced delayed
                             neurotoxicity in an
                             experimental species
                             will be required.

Reentry time reassessment.   Data necessary to reassess
                            the 24-hour reentry time
                            for EPN were required.

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                             -10-

7.  Data Call In (PCI)

     The Agency issued a Data Call In (DCI) Notice  on
May 31, 1985 requiring teratogenicity , reentry protection,
and delayed neurotoxicity data.  These data have  been  received
and reviewed by the Agency and are discussed below  in  the
Preliminary Health Risk Assessment section III. B.

     The Agency issued another DCI Notice on December  19,  1986
to all EPN registrants, including the basic registrant of
technical EPN, Marubeni America, Inc., for all of the  data
gaps identified in this registration  standard.  The Agency
chose to proceed with the issuance of the data requirements
in December 1986 without this document because the  Agency
had not completed its assessment of critical toxicology
data which was to be  incorporated into this document.   This
Registration Standard provides a review of these  and other
data and a reassessment of the RPAR regulatory decisions.

     On March 26, 1987 Marubeni America presented to the Agency
its decision that it would not generate and submit  these required
data and that it requested a voluntary cancellation of  its EPN
product registration.  As a result of Marubeni's  action, the
Agency reissued the December 1986 DCI Notice on March  26,  1987
to all other remaining EPN registrants (i.e. formulators)
informing them that the Agency could not exempt them from
producing the required data to support continued  registration
of their EPN products since all the registrants of  technical
EPN had chosen to voluntarily cancel  or suspend their  EPN
registrations.

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                             -11-

                       C.  Use Profile

     EPN is a broad spectrum non-systemic, slightly  persistent,
contact and orally active organcphosphate insecticide and
acaricide that has been marketed in the United States for
over 35 years.  There are currently no active registrations
for Technical EPN in the United States.

     There are currently 5 single active ingredient  products4
and 27 multiple active ingredient products5 registered.
Single active ingredient formulations currently registered
consist of:

     Product Type                 Percent Active Ingredient

     Granular                     (2% and 4%)
     Wettable Powder              (25%)

Single active ingredient formulations formerly registered
included:

     Technical                    (93%)
     Formulation Intermediate     (80%)
     Emulsifiable Concentrate     (2 Ib/gal, 4 Ib/gal,
                                   and 5 Ib/gal)

     (All liquid formulations and any formulation greater than
      4% active ingredient are classified as restricted use
      pesticides).

     EPN is registered for use on a variety of terrestrial
food crop and terrestrial nonfood sites and can be foliarly
broadcast using aerial or ground equipment.  Applicators are
required to be certified or under the direct supervision of
applicators certified to apply EPN.  Major use sites include
cotton, soybeans, field corn, and pecans.  Other registered
uses include almonds, apples, apricots, beans (green beans,
-lima beans, navy beans, red kidney beans, snap beans),
black-eyed peas, cherries (sweet and sour), citrus (citron,
grapefruit, lemons, limes, oranges, tangelos, tangerines),
corn (sweet), cowpeas, grapes, kumquats, nectarines, olives,
peaches, pears, pecans, plums, prunes, sugar beets, tomatoes,
walnuts, and earthworm farms.

     EPN is used to control insects such as the peach twig borer,
spider mites, codling moth, plum curculio, fruittree leafroller,
4 Single active ingredient products registered include
  5 under FIFRA Section 3.

5 Multiple active ingredient products registered include
  23 under FIFRA Section 3, 3 under FIFRA Section
  24(c), and 1 Intrastate.

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                             -12-

pear psylla, cottony peach scale, Lecanium scales, olive scales,
oriental fruit moth, lesser peachtree borer, peachtree  borer,
army worm complex, beet webworm, thrips, tomato fruitworm,
European corn borer, Mexican bean beetle, twospotted spider mite,
aphids, flea beetles, leafhoppers, Lygus bugs, climbing  cutworms,
darkling beetles, stink bugs, citrus red mites, citrus  thrips,
orange tortrix, orangeworms, corn rootworms, southwestern corn
borer, cabbage looper, cotton leaf perforator, tomato russet
mite, grasshoppers, boll weevil, bollworm, pink bollworm,
tobacco budworm, grape berry moth, grape leafhopper, walnut
caterpillar, hickory shuckworm, pecan weevil, may beetles,
pecan leaf casebearer, pecan nut casebearer, spittlebugs,
blister beetles, and corn earworm.  (Refer to Appendix  III,
"EPA Index to Pesticide Chemicals", for usage rates, calculations
of amount of active ingredient used, and complete listing of use
sites and pests.)

     EPN was first  registered for use in 1950 but was not
heavily utilized until the mid to late 1970s following  the
cancellation of DDT.  From annual usage levels in excess of
four million pounds of active ingredient (A.I.), a declining
trend began by 1980 as the newly developed synthetic pyrethroids
started to replace  organophosphates in the cotton market.

     The current aggregate annual usage estimate of 975,000
pounds of A.I. is considerably less than the 1.7 to 3.2 million
pounds of A.I. presented  in  the Agency's 1983 Preliminary
Quantitative Usage  Analysis.  The continued future use  of
EPN on cotton is expected for early season applications and
for years of heavy  target pest infestations; future usage
could  increase if pest resistance develops for the pyrethroids.

     Approximately  99% of the total amount of EPN use in the
United States in 1985 was attributed to use  on major cotton,
soybeans, field corn, and pecan pests.  These four use  sites
comprise about 91%, 3%, 5%, and <1% respectively, of the
annual EPN usage.   Recommended application rates range  from
0.125 to 5.0 Ib. active ingredient per acre  (a.i./A).   The
percent of the four use sites treated with EPN are 3%,  <1%,
7%, and <1%, respectively.

     California  and Federal  reentry intervals of 14 days and
24 hours, respectively, have been established for EPN.
(However, the Agency new  has adeguate data to establish interim
reentry levels for  all crops as detailed below in Section III. B.
of  this Registration Standard.)

     Tolerances  are established for use of EPN on certain fruit, nut,
field and vegetable crops.

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                              -13-

                      III.  AGENCY FINDINGS

                           A.  SUMMARY

 1.   Summary  of  Agency Conclusions

      The Agency has reviewed  all data currently supporting the
 registration of EPN.   Based on  the  review of  these data, the
 Agency  has reached  the conclusions  listed below.  These conclu-
 sions are  presented in more detail  in subsections III B, III C,
 and  III D below.

      a.    EPN has been demonstrated to cause  delayed neuro-
           toxicity  in the  domestic  hen.   The  effects have been
           expressed as ataxia and damage  to the sciatic nerve
           and spinal  nerve cord.

      b.    There are inadeguate  margins of safety (MOSs) for
           delayed neurotoxicity from dietary  exposure to crops
           treated with EPN and  from worker exposure associated
           with  applying EPN and reentering treated fields.

      c.    EPN is acutely  toxic  to honeybees.   Sufficient residues
           remain on treated crops  for two to  three days after
           application to  present an acute hazard to honeybees.

     As a  result of this assessment  under the Registration
 Standard process, the Agency  has determined that the delayed
 neurotoxicity characteristics for EPN meet  or exceed the delayed
 toxic effect risk criterion (40 CFR 154.7(a)(2)) for Special
 Review.  Also, the Agency has determined  that certain additional
 or revised label restrictions are necessary to reduce worker
 and environmental exposure during the  period  necessary to
 complete  the Special  Review.  These  include:

     Restricted Use Classification  with Corresponding
           Statement of  Reason
     Protective Clothing
     Reentry  Intervals

     The Agency has also identified  missing data necessary  to
 more fully evaluate the human and environmental  risks  associated
with the use  of EPN.   These data must  be  developed  in order to
 maintain registrations  of existing products or register  any
 new products  containing EPN.   All data submitted  to  the  Agency
must comply with PR Notice 86-5.  A summary of the data  gaps
for EPN is given in Table 2.   Note that this  is  only  a summary
and that complete details can be obtained by referring to the
tables  in Appendix I.

     The Regulatory Position and Rationale  section of  this
Registration Standard discusses the Agency's position  on each
of the  regulatory issues concerning EPN,  and  the Required
Labeling section contains the specific wording changes for
each of the  labeling provisions necessary  in  order for EPN
products to remain  in compliance with the requirements of FIFRA.

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                             -14-

Table 2.  Summary of Data Gaps for EPN.

(Refer to the tables in Appendix 1 for detailed information
regarding these requirements.  Also note that all data submitted
 to the Agency must comply wi th PR Notice 86-5.)


Toxicology

Acute delayed neurotoxicity - single dose NOEL
Dermal sensitization
Chronic toxicity          (two species - rodent and non-rodent)
Oncogenicity study        (two species - rat and mouse preferred)
Reproductive study
Metabolism


Environmental Fate

Hydrolys i s
Photodegradation, water
Photodegradation, soil
Aerobic metabolism
Anaerobic metabolism
Leaching and adsorption/desorption
Soil dissipation
Long-term soil  dissipation
Rotational crop (confined)
Rotational crop (field)
Fish accumulation
Droplet size spectrum
Spray drift field evaluation


Ecological Effects

Avian reproduction study
Fish early life-stage  study
Aquatic invertebrate life-cycle study
Aquatic monitoring or  mesocosm study
                   [continued on page 15]

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                             -15-

Table 2.  Summary of Data Gaps for EPN.  (continued)



Residue Chemistry

Storage stability study
Plant metabolism study
Animal metabolism study
Residue data for almonds, apples,  apricots,  beans (snap and lima),
   cherries, citrus, grapes, lettuce,  nectarines, olives,  peaches,
   pears,  pecans, plums,  soybeans,  sugar beets (without tops), and
   walnuts.
Residue data and usage proposal for beets and beet greens,
   blackberries, boysenberries, dewberries,  loganberries,
   pineapples,  quinces, raspberries, rutabagas,  spinach,
   strawberries, turnips  and turnip greens,  and youngberries.
   (tolerances for these items will be revoked if residue  data
   and usage proposals are not submitted)
Processing data for residues of EPN in sugar beets,  soybeans,
   tomatoes, citrus,  prunes, grapes, apples, cottonseed, corn,
   and olives.
Residue data and tolerance proposals  for bean vines and hay,
   sugar beet tops.

Special Processing Studies to provide:
   0 Residue data for cooked (microwaveing and boiling) sweet  corn.
   0 Residue data on fresh unwashed tomatoes
   0 A washing study to provide residue  data on lettuce

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                             -16-

2.  Summary of New Agency Positions Based on Information and
    Assumptions Used in the Current Assessment of Risk

     a.  NOEL Used

          In the EPN RPAR published in 1983 (48 FR 39494) the
     Agency relied primarily on the NOEL of 0.1 mg/kg/day for
     EPN-induced depression of plasma and RBC chplinesterase
     levels in humans as the NOEL for delayed neurotoxicity.
     On that basis, the Agency calculated dietary and applicator
     risks posed by continued uses of EPN.  The Agency concluded
     that adeguate MOSs existed for human dietary exposure and
     for applicators with the exception of flaggers.  The Agency
     used the cholinesterase-inhibition data to establish the
     NOEL because they we re the best data available  at the  time.

          Information received since that time on various
     cholinesterase-inhibiting compounds  indicates an effect
     on blood cholinesterase is not necessarily the  most
     sensitive indicator of toxicity for  organophosphates.
     This means that using the effect of  EPN on human blood
     cholinesterase may not be appropriate for determining
     human sensitivity to this compound, particularly for
     its delayed neurotoxic effect.

          New information on recovery after a single large
     dose of EPN in hens (Huntingdon Research Centre Ltd.,
     Report No. NSA 19(b)/86335, June 20, 1986) indicates
     that the spinal histopathological changes are irreversible.
     This finding has led the Agency to conclude  that the most
     appropriate NOEL to use for risk assessment purposes and
     the most sensitive indicator of potential human toxicity
     for this histopathological effect is 0.01 mg/kg/day from
     the 90-day subchronic feeding study  in hens.

          Using this NOEL to calculate risk from  dietary
     exposure to EPN, the Agency believes that the MOSs are
     not adequate for applicators and mixer/loaders  exposed
     to EPN.  The Agency also believes that the MOSs are not
     adequate for human adults and children who eat  more than
     average amounts of corn and tomatoes during the fresh
     market season.  Therefore, the Agency has determined that
     a Special Review of the chemical for the potential delayed
     neurotoxic effect  is necessary.

     b.  Reentry

          In the 1983 RPAR document, the Agency did  not
     calculate potential risk to workers reentering  fields
     treated with EPN because there were  no dislodge able
     residue data available on which to calculate exposure.
     Data received since that time have enabled the  Agency  to

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                             -17-

     conduct an exposure and risk assessment  for five  crops.
     The resulting MOSs are apparently  inadequate.   Therefore,
     the reentry intervals must be revised as discussed  below
     in Section IV. A. 5. (Regulatory Position  and Rationale).

     c.  Margin of Safety Limits

          In the 1983 RPAR document, the Agency considered
     that a MOS of 10 relative to the blood cholinesterase
     NOEL in the human study was adequate; any  number  below
     10 was deemed inadequate in view of the benefits  derived
     from the use of EPN.  However, because the new  recovery
     study shows that the spinal histopathological changes in
     the hen are irreversible, a MOS of at least 100 is
     considered necessary.  The spinal histopathological
     changes have been shown to be the most sensitive
     indicator for potential human toxicity.

3.  Summary of Agency Position on Other Effects

     In the 1979 RPAR, the Agency identified 5 other possible
adverse effects of EPN for which insufficient information
existed to issue a rebuttable presumption.  The following
paragraphs summarize the Agency's current position on  these
effects.

     a.  Teratogenicity

          Two acceptable studies in the rat and rabbit do not
     demonstrate teratogenic effects.  These studies are
     described in detail in Section III. B. 5. below.  The
     Agency has determined that EPN has not been shown to
     be teratogenic.  No further teratology data are required
     by the Agency at this time.

     b.  Cholinergic Effects

          EPN produces clinical signs of toxicity secondary  to
     its inhibition of cholinesterase.  These signs  are a result
     of accumulation of acetylcholine in the organism  and are
     cholinergic responses.   The delayed response shortly after
     dosing is indicative of a secondary cholinergic response.
     The Agency concludes that there is no evidence  that EPN
     has a direct effect on cholinergic receptors.    However,
     because EPN has been shown to be acutely toxic  due to
     inhibition of cholinesterase,  the Agency is requiring a
     Restricted Use Classification.

     c..  Disorders of the Eye

          The 1979 Position Document stated that one study in
     Japan indicated that eye disorders such as reduced vision,

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                             -18-

    narrowing  of  the  visual  field,  abnormal  refraction  and
    other abnormalities were observed.   However,  the subjects
    were  exposed  to several  pesticides,  not  just EPN, and the
    amount of  EPN exposure was not  determined.   Since  that time
    the Agency has been unable to find  evidence  that EPN causes
    disorders  of  the  eye,  thus reaffirming its position in the
    original  1979 RPAR that  a risk  criterion for  this  effect
    has not been met  or exceeded.

    d.  Mutagenicity

          Information  on mutagenic effects is detailed  below in
    Section III.  B. 7.  The  Agency  concludes, based  on  all
    mutagenicity studies submitted  and  reviewed,  that  EPN
    is  not mutagenic.

    e.   Reductions in Honeybee Populations

          The Agency has reviewed data which  show that  EPN
     is highly  toxic  to honeybees (Atkins et al. ,  1975).
    The Agency concluded that labels of  end-use  products
     intended for foliar application must contain a bee
    precaution statement.  Section  IV.  D. of this
    Registration Standard continues this requirement.

     f.   Potentiation

          In the 1979  RPAR position document the Agency  stated
    that  animal studies indicated that  EPN was observed to
    potentiate (enhance) the acute toxicity of malathion,
     dimethoate, and systox.   The Agency requested information
     regarding  use practices  in the United States to determine
     whether these pesticides were actually used in combination
    with each  other.   E.I. Du Pont de Nemours responded to the
     RPAR and pointed  out that there are  no registered  products
    which contain EPN in combination with these other pesticides
     and that tank mixes are  not used either.  Because  it does
     not appear that  these products are used in combination the
    Agency concludes  that the risk  of potentiation is  not now
     of concern.
                  B.  HEALTH RISK ASSESSMENT

     The Agency has reviewed EPN data in the areas of acute
toxicity, chronic toxicity, oncogenicity, reproductive effects,
mutagenicity, environmental fate and exposure, and ecological
effects.  Numerous data gaps exist.  The following assessment
is based on available data and is subject to change when the
results of the required studies are available for Agency review.

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                             -19-

1.  Acute Toxicity

     Adequate data are available to fully assess  the  acute
oral, dermal, and inhalation toxicity of technical  EPN.   These
data indicate a high acute oral toxicity to mammals with LDso
values of approximately 52.8 and 13.2 mg/kg/body  weight  in male
and female rats, respectively (E.I. du Pont de Nemours &  Co.,
Inc., 1949); acute dermal LDso values of 354 and  500  mg/kg/body
weight in male and female rabbits, respectively (International
Research and Development Corp., Study No. 163-495, Nov.  8,
1977); and acute inhalation LD$Q values of 0.076  and  0.024
mg/liter (1) in male and female rats, respectively  (Haskell
Laboratory Report No, 32-71, Feb. 5, 1971).  These values
place EPN in Toxicity Category I on the basis of  acute oral
toxicity; Toxicity Category II on the basis of acute  dermal
toxicity; and Toxicity Category I on the basis of acute
inhalation toxicity.

     Sufficient data are also available for the Agency to
conclude that technical EPN does not produce eye  irritation
or dermal irritation (International Research and  Development
Corp., Dec. 29, 1975 revised Mar. 16, 1976).  Technical  EPN is
in Toxicity Category IV on the basis of dermal irritation.

     There are no dermal sensitization studies available  on
technical EPN; therefore, this effect cannot be assessed.
The Agency is requiring a dermal sensit ization study.

     The Agency has sufficient data to determine  that technical
EPN produces organophosphate type delayed neurotoxicity in  the
hen (Huntingdon Research Centre Ltd., NSA 19(a)/8646, May  9,
1986).  The acute oral LDso of EPN in adult hens  was  determined
to be 171 mg/kg.  A single oral dose of 175 mg/kg EPN produced
organ ophosphate type delayed neurotoxicity.  Eight of the
surviving birds showed signs of delayed neurotoxicity.  Neuro-
pathological abnormalities in excess of those observed in control
animals were observed in 10 of 11 EPN dosed birds.

     The Agency does not have a study on which to base a NOEL
for spinal histopathological changes for a single toxic dose;
therefore, an acute delayed neurotoxicity study must be submitted
by the registrants.

2.  Subchronic Toxicity

     Adequate data are available to satisfy the data  requirements
for subchronic oral toxicity studies in a rodent and a nonrodent
species.   In a subchronic rat study (Hazleton Laboratories
America/ Project No. 2096-111,  Feb. 24, 1986), 10 animals of
each sex at each dose level were dosed with EPN orally for
13-weeks at doses of 1, 5, 25 and 125 parts per million (ppm)
in the diet.  Ten extra animals included in the high dose
group were maintained for a 4-week post-dose recovery period.

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                              -20-

EPN-related effects were depression  of  cholinesterase  activity
(plasma NOEL 25 ppm, red blood  cell  (RBC)  NOEL 5  ppm and brain
NOEL 25 ppm); decreased growth  in the females  at  125 ppm;
decreased erythrocyte  parameters  in  both sexes at 125  ppm;
and increased splenic  pigmentation  (hemosiderin)  in  the
females at all doses.

     In a subchronic dog study  (Hazleton Laboratories  America,
Project No. 2096-121,  Feb.  24,  1986), 4 animals  of each sex
at each dose level were dosed orally by capsule for  13-weeks
at doses of 0.3, 1.0,  and  3.0 mg/kg/day.   During  ophthalmoscopic
examinations at week 13, seven  of the eight  animals  at the
3.0 mg/kg/day dose  showed  EPN-induced miosis (constriction  of
the pupil of the eye).  An EPN-related  decrease  in red blood
cell parameters, indicative of  increased destruction and/or
early breakdown of red blood  cells,  was observed  in  the high
dose males at treatment weeks 4,  7  and  13.  The same values
were depressed in females  at  the high dose,  but  there  was
some indication of  recovery at  week  13.  Plasma  cholinesterase
activity was reduced in the 3.0 mg/kg/day  group in both sexes
at 4, 7 and 13 weeks and  in the 1 mg/kg/day  males at 4, 7 and
13 weeks (p £ 0.05).   RBC  cholinesterase activity was  decreased
in the 3 mg/kg/day group  in both  sexes  at 4, 7 and  13  weeks
(p _< 0.05).  Brain  cholinesterase activity was significantly
decreased at 3.0 mg/kg/day in both  sexes (p £ 0.05).  The
authors of the study stated "The most remarkable  histopatho-
logical finding in  the treated  animals  was pancreatic  acinar
cell atrophy present in two Group 4  males."

     Sufficient data are  available  to  the Agency  to  satisfy the
requirement for a 21-day dermal study in rats (Hazleton Labora-
tories Ame rica, Project No. 209-6120, Oct. 29, 1985).   In this
study rats were randomly assigned to the following groups.

                                       EPN  Technical
         No. of Animals           Dosage Levels (mg/kg/day)a
Group
1
2
3
4
5
Males
5
5
5
5
5
Females
5
5
5
5
5
Males
0
2.5
7.5
25.0
75.0
Females
0
0.5
1.5
5.0
15.0
   All  applications  were given in a dosage  volume  of  1.0 ml/kg
   in acetone  solvent.

EPN  applied  dermally  for 21-days produced signs typical of
organophosphate  toxicity at the  highest doses (75  mg/kg/day
for  the males  and  15  mg/kg/day for the females).   A NOEL for
the  most sensitive effect,  cholinesterase inhibition  in plasma
and  RBC, was demonstrated at 0.5 mg/kg/day.

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                             -21-

     No data are available to the Agency on  the  90-day dermal
toxicity of EPN.  However, based on  the expected exposure,  the
Agency is not requiring a 90-day dermal toxicity study.

     The Agency has adequate data to  characterize  the 13-week
inhalation toxicity of EPN in rats (Hazleton Laboratories Europe
Ltd., Report No. 5160-306/13, July 1986).  In  this study  ten
rats per sex per dose were tested at  0.093,  0.731  and 7.859
micrograms per  liter (ug/1) for male  rats  and  0.0094, 0.093  and
0.731 ug/L for  female rats.  The only effect observed was
depressed RBC cholinesterase activity in the high  dose males.

     Sufficient data are available to the Agency to  show  that
EPN produces organophosphate type delayed neurotoxicity in two
90-day oral studies in the chicken.

     In the first study by Abu-Donia and Graham  (Toxicology
and Applied Pharmacology 45:685-700;  1978) hens  (6 per dose)
were dosed at 0.01, 0.1, 0.5, 1.0, 2.5 and 5.0 mg/kg/day  by
capsule.  Signs of neurotoxicity were observed at  doses of 0.1
to 5.0 mg/kg/day with a NOEL of 0.01 mg/kg/day.   Histopathological
evidence of neurotoxicity (neuronal degeneration)  were  detected
in the spinal cord at doses of 1.0 mg/kg/day and higher.  A  dose
of 0.5 mg/kg/day was a NOEL for this  effect.

     In the second study (Huntingdon Research Centre,  DAS 2181637,
Mar. 3, 1982) hens (20 per dose) were dosed  at 0.01,  0.1, 0.5,
1.0, 2.5 and 5.0 mg/kg/day by capsule.  Signs  of neurotoxicity
were observed at doses of 2.5 and 5.0 mg/kg/day  with a NOEL  of
1.0 mg/kg/day.  Histopathological evidence of  neurotoxicity
(neuronal degeneration) was detected in the spinal cord at
doses of 0.1 mg/kg/day and higher.  A dose of  0.01 was a  NOEL
for this effect.  This study is discussed in detail  below in
Section III. B. 10.

     After reviewing all of the subchronic toxicity  studies,
the Agency has determined that a dose of 0.01 mg/kg/day for
histopathological effects is the most sensitive  NOEL  on which
to base a human risk assessment.

3.  Chronic Toxicity

     No data are available to the Agency on the  chronic oral
toxicity of technical EPN in rodent and nonrodent sepcies.  The
Agency is requiring a two-year feeding study in  the  rat and  a
one-year feeding study in the dog.

4.  Oncoqenicity

     No data are available for the Agency  to evaluate  the
oncogenic potential of  technical EPN.  The Agency is requiring
life-time feeding studies in the rat and the mouse.

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                             -22-

5.  Teratogenicity

     Sufficient data are available  in the  rat and the  rabbit  to
satisfy the requirements for teratology studies of  EPN.

     In a teratology study in the rat (Hazleton Laboratories
America, Report No. 2096-115, Sept. 4,  1986), 25 females per
dose were dosed at 0.3, 0.6, 1.2 and 2.4 mg/kg/day  during
days 6 - 15 of gestation.  Clinical signs  of EPN toxicity  were
observed in the high dose females and consisted of  tremors,
prostration, urine stains, hunched  appearance, bloody  crust
on the eye lids and nose, rhinorrhea and lacrimation.   No  fetal
toxicity was observed at the highest dose  tested.

     In a teratology study in the rabbit (Hazleton  Laboratories
America, Report No. 2096-116, Sept. 4,  1986), 15 females per
dose were dosed at 1, 3, 6 and 9 mg/kg/day during days 7-19
of gestation.  Twelve females died  or were sacrificed  due  to
morbidity at 9 mg/kg/day.  Signs of toxicity including languidness,
prostration and salivation were observed in the does sacrificed
and in the survivors.  Two 6 mg/kg/day  females were found  dead.
No signs of toxicity were observed  in these females.   The  only
possible compound-related effect on the fetuses was significantly
lower mean fetal  body weights in the females at 6 and  9 mg/kg/day.

     The Agency has determined, based on these two  studies, that
EPN has not been  shown to be teratogenic.

6.  Reproduction

     No data are  available for the  Agency  to evaluate  the
effects of EPN on reproduction.  The Agency is requiring a
reproduction study in the rat.

7.  Mutagenicity
     The Agency has sufficient data to  evaluate the mutagenic
potential of EPN.  EPN technical was weakly mutagenic  in a
single  replicate  of one  of the tests utilized.  Based  on all
mutagenicity tests submitted, it is concluded that  EPN is  not
mutagenic.

     Two gene mutations  studies were available.  The first study
(Microtest Research Ltd., Study No. NCJ1/S/AF4/SA3, Oct. 22,  1985)
was performed to  determine the ability  of  technical EPN to induce
mutation in four  histidine-requiring strains of Salmonella
typhimurium.   EPN was not mutagenic in Salmonella  typhimurium
strains TA98, TA100, TA1535 or TA1537 at doses up to 2500  ug/plate
either with or without metabolic activation.

     The second study  (Microtest Research  Ltd., Study  No.
NCJ1/MLK/KF20/ML3, Apr.  7, 1986) was performed to determine the
ability of technical EPN to induce  mutation to 6-thioguanine
resistance  in mouse lymphoma L5178Y cells. EPN was weakly

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                              -23-

tnutagenic in one of two replicates, in mouse  lymphoma  L5178Y
cells  in vitro  in  the presence  of liver S-9 fraction.   Mutagenic
activity was approximately 1/1000 to  1/500 of  the  positive
control.  Because  of the ambiguity and weakness  of  the  results
obtained, the study cannot be considered  definitive in and  of
itself.

     Two chromosomal aberration studies were  available.   The
first  study (Microtest Research Ltd., Study No.  NCJ1/CHO/KF17/CH3,
Oct. 22, 1985)  was performed to evaluate the  chromosome damaging
potential of EPN technical by its effects on  cultured Chinese
hamster ovary (CHO) cells using an in vitro cytogenetic assay.
EPN technical,  at  doses up to 5000 micrograms  per milliliter
(ug/ml), did not cause an increase in chromosomal aberrations
when tested on  cultured Chinese hamster ovary cells either  with
or without metabolic activation with  rat liver S-9  fraction.
     The second study (Microtest Research Ltd., Study No.
NCJ1/MNT/KF19/MN1, Oct. 22, 1985) was performed to evaluate  the
potential of technical EPN to induce micronuclei in the bone
marrow of treated mice.  EPN did not induce micronuclei in the
bone marrow of mice treated with a single oral dose of 30 mg/kg.

     One unscheduled DNA synthesis study (Microtest Research Ltd.,
Study No. NCJl/He/KFl6/HE2, Oct. 23, 1985) was performed to
determine the ability of technical EPN to induce unscheduled
DNA synthesis in HeLa Cells.  EPN, at doses up to 500 ug/ml,
does not induce unscheduled DNA synthesis in HeLa cells either
with or without metabolic activation.

8.  Metabolism

     The Agency has data to partially satisfy the requirement
for a metabolism study of EPN in rats.

     In these studies (Hazleton Laboratories Europe,  Report No.
4958-306/14, April 1986) EPN was administered orally, by gavage,
as a solution in corn oil to the dose groups.  Noted  below are
the findings of the excretion study and pharmacokinetic study:
Excretion study:
  Group
    B
Sex
Males
Females

Males
Females

Males
Fema1e s
Number
  5
  5

  5
  5

  5
  5
      Dose EPN
                                Unlabeled EPN
                                mg/kg/day
0.8 (14 days)
0.3 (14 days)
Labeled iliC
mg/kg/day

  0.8
  0.3

  0.8
  0.3

 30.0
 15.0
                                                 EPN1
  *Labeled EPN
   in order to
   organisms.
    is EPN that has a radioactive isotope added
    trace its course and behavior in living

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                             -24-

In both sexes labeled  14C  EPN  was  excreted  by  urine  and feces
over a period of 5 to  6 days for the  low  dose  and 7  days for
the high dose.  Excretion  appears  to  be biphasic,  with  the
majority of the labeled EPN excreted  in 48  hours for both low
and high doses.  Pretreatment  with  unlabled EPN for  14  days
increased the relative portion of  labeled EPN  excreted  in the
urine and during the first 12  hours in both sexes.   This also
reduced the total excretion time to four  days,  indicating
induction of metabolizing  enzymes.  Because different doses
were used for each sex in  each dose regimen,  it was  impossible
to compare the relative excretion  by  sex.  As  there  is  approxi-
mately a seven fold  difference in acute toxicity by  sex (it is
more toxic in females), this is  a  critical  deficiency in the
study-  The male portion of the study must  be  repeated  using
the doses that were  used for the females.

     The effect of the pretreatment dose  regimen on  the portion
of the labeled EPN excreted in the  urine  in both males  and females
also  indicates that  biliary excretion may be responsible for
all or part of the fecal excretion  observed.   An experimental
evaluation of this possibility is needed.

     Analysis of urine and feces showed the existence of several
possible metabolites.  However,  these were  not identified.
Further work must be performed to  identify  the metabolites.

     Tissue analysis showed relatively  higher concentrations of
radioactivity in kidney, lung  and  liver.  There appear  to be
some  dose-related differences  in this residue.   Due  to  the use
of different doses for each sex, it is  impossible to determine
if there are  sex-related differences.   The  quantities remaining
in these organs do not appear  to be toxicologically  significant.

Pharmacokinetic study:

  Group    Sex        Number            Dose  EPN*
                                   Labeled 14C  EPN
                                   rag/kg/day

    A      Males       5               0.8
           Females     5               0.3

    C      Males       5              30.0
           Females     5              15.0

  *Labeled EPN is EPN  that has a radioactive isotope added
   in order to  trace its course and behavior in living
   organisms.  Only  labeled EPN was used  in this kinetics study-

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                              -25-

This kinetics study showed  peak blood  concentrations 12 hours
after  dosing for both doses and sexes.   The clearance curve
appears to be biphasic.   Again/ the  use  of different doses in
each sex  makes  sex-related  comparisons impossible.   This is a
scientific deficiency,  but  since  this  study is  not  required it
is  not  considered  a regulatory  deficiency.

9.  Neurotoxicity  Recovery  Study  in  Hens

     In order to satisfy  an Agency requirement,  a study was
performed to determine  the  ability of  hens to recover from a
single  oral dose of EPN (Huntingdon  Research Centre Ltd.,
Report No. NSA  19(b)/86335, June  20, 1986).  A  dose of 175 mg/kg
in atropine-protected hens  was  selected  as capable  of producing
signs  of  organophosphate  delayed  neurotoxicity  (ataxiaj  in
approximately half of the treated hens without  producing
excessive lethality.

     A total of  80 hens were  protected with atropine against
acute  toxicity  and given  a  single oral dose of  175  mg/kg EPN.
All treated hens and 10 untreated controls  were observed and
graded for ataxia.  Groups  of five treated hens were sacrificed
for histopathology of selected  parts of  the  central  nervous
system  (CNS) and sciatic  nerve  at intervals  for up  to 90 days
post dose.  Five controls were  sacrificed  at 45 days  and 5  at
90 days.

     A total of  20 hens showed  delayed ataxia during  the study.
Some of the birds  which showed  ataxia, and were retained for
sufficient time, showed improvement  and  recovery.   Five  hens,
with mild class  1  or 2  ataxia recovered  fully and 7 hens  with
more severe ataxia showed some  measure of  improvement in gait.
Histopathology showed mild damage to the sciatic nerve in all
20 hens and complete nerve  recovery  with time.  After the 40-day
sacrifice all samples were normal.  However, relatively  severe
damage (grade III  and IV) was observed in  the spinal  cord and
recovery was relatively minor.  There was  no correlation  between
the severity of  the histopathology of  the  spinal  cord and the
oceurance of signs of toxicity.  All 48 hens sacrificed  at
40 days, and later, showed grade  III and/or IV histopathological
damage in the cord, yet only 12 of these hens showed  signs  of
neurotoxicity (ataxia).  By this  time  the  sciatic nerves and
branches were normal.   There was nothing in  the spinal cord
histopathology to  distinguish any single hen showing  signs  of
neurotoxicity from the hens which did not show neurotoxicity.

     A reexamination of the histology  slides from the 20 hens
could not distinguish between the hens hens  which showed  ataxia
and those -which did not.

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                             -26-

10.  Toxicological Issues Associated with Delayed Neurotoxicity

     Organophosphate delayed neurotoxicity was  first  observed
in man during the prohibition era in the United States.   A
drink called Jamaica Ginger was contaminated with tri-o-cresyl
phosphate (TOCP) , a component of the organic solvent  used to
prepare ginger extract.  Humans exposed to the  contaminated
ginger extract developed a paralysis of the legs and  arms.
The severity of  the paralysis varied with the victim's  exposure
to the contaminant.  Animal studies identified TOCP as  the
toxic agent and  characterized this  paralysis syndrome which  is
now called Organophosphate Type Delayed Neurotoxicity.   Subsequently,
this syndrome was observed following accidental human exposure
to the pesticide leptophos and the  experimental compound  mipafox,
both of which are Organophosphate  inhibitors of cholinesterase.

     Organophosphate type delayed neurotoxicity is characterized
as follows:  1)  A delay  in the order of 10 - 14 days  between a
single effective dose and the appearance of clinical  and  histo-
pathological signs;  2) The appearance  of the delayed  effect  well
after recovery from the  acute toxicity of the compound;  3) No
apparent relationship between the  compound's ability  to inhibit
blood cholinesterase and its ability to produce the delayed
effect; 4) The appearance of abnormalities of gait which  may
proceed to complete paralysis and are  generally irreversible;
5) The destruction of nerve axons  in the sciatic  nerve  and the
spinal cord and  the subsequent disappearance of the myelin sheath
which surrounded the lost axons; and 6) The delayed toxic effect
can also be produced by  daily administration of doses which
individually will not produce the  acute toxic  response,  i.e. , the
delayed toxicity is  cumulative.

     Animal studies  with TOCP showed that the  toxic syndrome
could not be produced in rats and  mice and was  produced only
with  inconsistent or atypical results  in dogs  and cats.   The
syndrome has been demonstrated in bovine and primate  species.
The  chicken has  been shown to consistently demonstrate  the
syndrome with the three  compounds that are active in  man  and/
for practical purposes,  has become  the species  of choice  for
detecting this toxic effect.

     Several studies with EPN in  the chicken have demonstrated
the Organophosphate  delayed neurotoxic syndrome.  The studies
reviewed in this standard verify  the previous  reports.   They
characterize more precisely the dose and time relationship of
the  neurotoxic  effect  and provide  information  on  the  ability
of the experimental  animal to recover  from the  effect.

      In the acute oral  study  (Huntingdon Research Centre Ltd. ,
NSA  19(a)/8646,  May  9,  1986), a  nominal LDso of  175 mg/kg EPN
produced signs of delayed neurotoxicity in 8 of 14 hens  which
survived the acute  lethality.  Histopathology  characteristics
of the syndrome  were observed in the spinal cord and  sciatic
nerve.

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                              -27-

     Two  90-day  oral  dosing  studies  summarized above in Section
III. B. 2.,  were performed in hens and used  the  same doses.
These  studies  provided  contradictory  evidence as to a NOEL.
The  doses used were 0.01, 0.1,  0.5,  1.0,  2.5 and 5.0 mg/kg/day
by capsule.

     In the  first  study Abou-Donia (Toxicology and  Applied
Pharmacology 45:685-700; 1978)  reported the  NOEL for neurotoxic
signs  (ataxia) as  0.01  mg/kg/day.  The histopathologically
determined NOEL was reported  as 0.5 mg/kg/day.

     In the second study Huntingdon Research Centre (EAS 2181637,
Mar. 3, 1982)  reported  the NOEL for  clinical neurotoxic  signs
(ataxia)  as  1.0 mg/kg/day.   The histopathologically determined
NOEL was  reported  as  0.5 mg/kg/day.   However,  an evaluation
of the report  of this study  by  the Agency concluded that
histopathological  changes of  the spinal cord were observed at
doses  as  low as  0.1 mg/kg/day and that a dose  of  0.01 mg/kg/day
was a NOEL.  This conclusion was based on a  shift in the  relative
number of grade  I and II slides reported in  the  hens dosed at
0.1 and 0.5 mg/kg/day compared  with  the untreated controls.
Although  both  grades are considered within the range of
normality, the dosed hens showed  relatively  more grade II
slides than the controls.  Grade I has been  described as
showing no abnormalities and grade II as, "Disruption or
fragmentation  of occasional axons.  Myelin abnormalities  were
rare.  In general on  any slide  prepared from the spinal  cord
(two longitudinal and one transverse sections),  between one
and four  degenerate/ altered axons were detected.   On a  slide
of peripheral nerve one or two  degenerate axons  were included
in this grade."  The  ratings of  these histopathological  changes
in the spinal cord of  hens treated for 90 days with EPN at
various doses  is shown  in Table  3.

     The  most  sensitive NOEL of  0.0.1 mg/kg/day for  histopatho-
logical changes in the spinal cord was used as a basis for the
risk assessments discussed below in Section  11.

     The recovery study discussed above in Section  III. B. 9.
(Huntingdon Research Centre Ltd., Report No.  NSA 19(b)/86335,
Jun. 20,  1986) has provided new information on the  long-term
effects of a single dose of EPN on gait and  on histopathology
of the nervous system.  Humans and experimental animals
poisoned  by compounds  producing delayed neurotoxicity have
displayed  a measure of 'recovery1 in  locomotor activity with
time.  It is not known if this  recovery is due to reversal of
nerve damage, to compensation such as occurs  following stroke
or to  some .combination of both.   The recovery  study was designed
to provide experimental information on this  'recovery1: was it
real, and if so what was the possible mechanism.

     Of the hens which showed delayed ataxia  during the study,
five hens with a mild class 1 or 2 ataxia recovered fully  and

-------
                             -28-

seven hens with more severe ataxia showed some  measure of
improvement in gait.  Histopathology  showed mild  damage  to  the
sciatic nerve and complete nerve recovery with  time;  after
40-day sacrifice all samples were  normal.  In  the spinal  cord
recovery was relatively minor from a  generally  more severe
damage.  The Agency considers that this  cellular  destruction
in the spinal cord is serious because these cells  are never
replaced? the damage is permanent.

     An additional critical and unexpected observation was  the
lack of correlation between the severity of the histopathology
and the occurrence of clinical signs  of  toxicity  (ataxia).  All
48 hens sacrificed at 40 daysf and laterf showed  grade III  and/or
IV damage in the cord yet only 12  of  these hens showed ataxia.
By the time of sacrifice the sciatic  nerves and branches  were
normal.  There was nothing in the  histopathology  to distinguish
any  single hen showing signs of ataxia  from the hens  which
did not show ataxia.
Table 3 - Ratings  of Histopathological Changes  in the Spinal
          Cord of  Hens Treated For  90 Days  With EPN
DOSE
O.OO
0.00
0.01
0.10
0.50
1.00
2.5
5.0
10.0
GRADE 1
I II III IV V
t
30
28
39
23
29
13
26
11
11
%
75
70
89
58
66
41
54
25
17
#
10
11
5
17
15
14
13
10
4
%
25
28
11
43
34
44
30
25
6
#
0
1
0
0
0
5
3
12
16
%
0
3
0
0
0
16
7
27
25
#
0
0
0
0
0
0
2
9
22
%
0
0
0
0
0
0
5
20
34
f
0
0
0
0
0
0
0
2
11
%
0
0
0
0
0
0
0
5
17
 1 The  gradings  of histopathological  changes  represent  an
 increase  in severity  from Grade  I  to Grade V.

-------
                             -29-

     This situation has never been reported  previously/  most
likely because this type of study, with periodic  serial
sacrifices occurring after 40 and through 90 days  following
a single dose of a delayed neurotoxin, had never  previously
been performed.  Acute studies containing a recovery phase
usually go only 30 days post dose and have no  interim sacrifices.

     The 90-day oral dosing study by Huntingdon Laboratories
(DAS 2181637, Mar. 3, 1982) included a 90-day  recovery period.
The study also used three doses of TOCP as a positive control.
Histopathological signs of nerve damage were clearly seen  in
the spinal cord for both compounds but, while  present, were
minimal in the peripheral nerve (sciatic and branches).  In
the spinal cord, effective doses of TOCP showed possible
deterioration and no evidence of recovery.  Effective doses
of EPN were equivocal in relation to recovery;  there is  some
indication of a dose-related recovery in the groups given
0.1 through 0.5 mg/kg/day , but there is also an indication
of deterioration at 0.01 mg/kg/day.  In the peripheral
nerve, recovery from both compounds could be considered
complete at 90 days post dose since the treated hens could
not be distinguished from the controls.

11.  Risk Assessments for Delayed Neurotoxicity

     To assess the risks to the public who consume EPN treated
food commodities and to workers involved with  application of EPN,
the Agency estimated dietary and worker exposures and compared
these to the NOEL for histopathological effects of delayed  neuro-
toxicity.  These comparisons are expressed as margins of safety
(MOSs) and the assessments are presented below.  The Agency  used
the NOEL of 0.01 mg/kg/day for histopathological effects in the
spinal cord,  derived from the Huntingdon Laboratories subchronic
feeding study in hens (DAS 2181637, Mar. 3, 1982).  Even if the
Agency used the reported, histopathologically determined NOEL of
0.5 mg/kg/day, the risk concerns expressed below would remain
unchanged.

     Dietary Risk Assessment

     Dietary exposure occurs from consumption  of food crops
treated with EPN.  The Agency assessed dietary exposure and
risk under three scenarios:  (1) EPN residues  on food ccmmo-
dities at the established tolerance levels and  assuming 100%
of the crop acreage is treated, (2) for five crops for which
the Agency has actual crop residue data; EPN residues are at
levels suggested by these data, and (3) scenario 2, except
assuming the appropriate percent of crop treated for each crop.

     In calculating the Maximum Permissible Intake (MPI) (for
comparison to dietary exposure), the following assumptions
were used:  the NOEL of 0.01 mg/kg/day, an average body
weight of 60 kg, a daily diet of 1.5 kg, and a  safety factor
of 1,000.  This level of safety factor (or uncertainty factor)
is considered appropriate for subchronic studies.  The Acceptable

-------
                             -30-

Daily Intake (ADI) was obtained  by multiplying the NOEL  of
0.01 mg/kg/day by the safety factor  of  1000  to yield 0.00001
mg/kg/day-  Assuming a person weighs 60 kg,  the MPI  was
calculated to be 0.0006 mg/day  (0.00001 X 60).

     Table 4 (Scenario 1) shows  the  percentages of the MPI for
EPN as a  function of consumed residues  based on an  individual
consuming commodities containing EPN at tolerance levels,  at
the given food factor levels, and consuming  1.5 kg  of  food
per day.  (The food factors represent the  percent of the
commodity eaten by a person  in  his/her  diet  each day).   The
total percentage of the MPI from all crops is 164,000%.  A
total percentage of the MPI of  up to 100%  is generally a
regulatory standard of acceptability.

     The Agency believes  that the resultant  figure  of  164,000%
MPI is not a-realistic estimate  because of the worst case
assumptions used in the calculation, such  as that 100% of  the
crop acreage is treated with EPN and that  all commodities  are
at tolerance level.  However, even  considering these exaggerated
assumptions the Agency is still  concerned  about the  dietary
exposure.

     The Agency has only  a limited  amount of data at this  time
for more realistic estimates of  EPN  residue  levels on  the
commodities and the percentages  of  the  crops' acreages that
are treated with EPN.  However,  for  five  crops (soybeans,  dry
beans, tomatoes, corn, and cotton) the  Agency has these  data.
Dietary exposure to EPN residues from these  five crops and
the percentage of the MPI were  assessed.   These assessments,
based on maximum observed residues based  on  field studies  and
percentage of crop treated, were compared  to assessments
based on these five crops at the tolerance levels and  100% of
the crop  acreages treated.  These assessments are presented
in Table  5.  Based on using tolerance levels and 100%  of the
acreage treated, the dietary exposure from these five  crops
results in 56,000% of the MPI.   However,  when the
assessment is corrected for  estimates of  highest expected
residue levels and percent acreage treated,  the percentage of
the MPI for these five crops falls  to 120%.

     In another dietary assessment of EPN  residues,  the  Agency
chose  three commodities  (cooked  corn, corn on the cob, and
fresh whole tomatoes) to  demonstrate the  chronic dietary
exposure  and the MOSs for the spinal histopathological effect
as calculated using the Tolerance Assessment System  (TAS).
(The TAS  is a computer-based tool which estimates dietary
exposure  to a pesticide and then compares  that estimate  to a
previously determined acceptable daily  intake.  The  TAS  data
files are composed of food comsumption  estimates  (based  on
dietary intake records for 30,770 individuals), toxicology
data on the chemical, and residue concentrations.) These MOSs

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                                  -31-
 Table 4  -  Dietary Exposure  and Its Percent of the Maximum Permissible
           Intake
       Crop
Almonds
Apples
Apr icots
Beans
Beets
Beet greens
Blackberries
Boysenberries
Cherries
Citrus fruits
Corn, all  types
Cotton seed (oil)
Dewberries
Grapes/ incl raisins
Lettuce
Loganberries
Nectarines
Olives
Peaches
Pears
Pecans
Pinneapple
Plums, incl prunes
Quinces
Raspberries
Rutabagas
Soybeans
Spinach
Strawberries
Sugar, cane & beet
Toma toes
Turnips
Turnip greens
Walnuts
Youngberries
ToleranceFood Factor1mg/day2Percent MPI
  (ppm)        (%)	    (1.5 kg diet)   	
  0
  3
  3
  3,
  3
  3,
  3
  3,
  3
  3,
  3,
  0,
  3,
  3,
  3,
  3,
  3,
  3.
  3.
  3.
  0,
  3.
  3.
  3.
  3,
  3.
  0,
  3.
  3,
  3.
  3.
  3.
  3.
  0.
.500
,000
.000
,000
,000
,000
,000
.000
,000
,000
,000
500
,000
000
,000
000
000
000
000
000
500
000
000
000
000
000
050
000
000
000
000
000
000
500
  3.000
 0
 2
 0
 2,
 0
 0,
 0
 0,
 0,
 3,
 2,
 0.
 0,
 0,
 1,
 0.
 0.
 0.
 0.
 0.
 0.
 0.
 0,
 0.
 0.
 0.
 0.
 0.
 0.
 3.
 2.
0.
 0.
0.
.03
.53
.11
.04
.17
,03
,03
,03
.10
,81
,51
 15
,03
 49
,31
 03
,03
 06
 90
 26
 03
 30
 13
 03
 03
 03
 92
 05
 18
 64
 87
 05
 03
 03
           0.03
 0
 0
 0
 0
 0
 0
 0
 0,
 0
 0,
 0
 0,
 0,
 0.
 0,
 0,
 0,
 0.
 0.
 0.
 0.
 0.
 0,
 0.
 0.
 0.
 0.
0.
 0.
0.
 0.
0.
0.
0.
.00023
.11385
.00506
.09180
.00782
.00135
.00135
,00135
.00460
,17154
.11295
,00112
,00135
,02207
,05887
,00135
,00135
00276
,04047
01150
,00023
01334
,00598
00135
00135
00135
00069
00230
00828
16372
12937
00230
00135
00023
               0.00135
     38
 18,975
    843
 15,300
  1,303
    225
    225
    225
    767
 28,590
 18,825
    186
    225
 3,678
 9,811
    225
    225
    460
 6,745
 1,917
    38
 2,223
    997
   225
    225
   225
    115
   383
 1,380
27,286
21,562
   383
    225
    38
   225
                                                          Total  =  164,317
Theoretical Maximum Residue Contribution
for a 60 kg person.
                   (TMRC)  is  0.9856 mg/kg/day
   In the calculation of daily dietary exposure, the Agency  used
   appropriate fo.od factors, i.e., the percent of that commodity
   eaten by the .general population in one day.  For example, almonds
   represent 0.03% of a person's daily dietary intake.
   The dietary intake was calculated assuming that 100% of each crop
   was treated with EPN; however, useage date indicate that  about  7%
   of corn is treated, 3% of cotton is treated and less than 1% of
   each of the remaining crops are treated

-------
                              -32-

Table 5 - Dietary Exposure From Five Crops Based  on Tolerance
                 Levels and 100% Crop Treated
Crop
Soybean Oil
Dry Beans
Tomatoes
Sweet Corn
Cottonseed Oil
TOTALS
Tolerance
(ppm)
0.05
3.0
3.0
3.0
0.5
Food
Factor( %)
0.92
2.04
2.87
2.51
0.15
Dietary Expo.
(mg/day ,
1.5 kq diet)
0.00069
0.09180
0.12937
0.11295
0.00112
0.33593
% of
MPI
115
15,300
21,562
18,825
186
55,988 %
  Dietary Exposure From Five Crops Based on Actual Residues
                   and Percent Crop Treated
Highest
Expect. Res.
Crop (ppm)
Soybean Oil
Dry Beans
Tomatoes
Sweet Corn
Cottonseed Oil
TOTALS
0.3
0.06
0.30
0.13
3.5
Food
Factor( %)
0.92
2.04
2.87
2.51
0.15
Dietary Expo.
% Crop (mg/day ,
Treated 1.5 kq diet)
<1 0.0000414
<1 0.0000183
<1 0.0001291
6 0.0002935
3 0.0002362
0.0006915
% of MPI
6.9
3.0
21.5
48.9
39.4
119.7

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                              -33-

are based on actual residues  in  these  commodities  and different
amounts of consumption  (average, 95th,  and 99th percentile) of
each commodity on a daily basis.  Table 6  presents the exposure
and MOS values for  the  U.S. population and for children.  The
MOSs are low for EPN exposure  for adults and  children who eat
more than average amounts of  corn and  tomatoes during the fresh
market season.

     Specifically,  for  fresh  cooked  corn the  MOSs  for the
general population range from  50 to  500 and for  children from
25 to 200 depending upon the  amount  of  daily  consumption and
the children's ages.  However, for these population  groups
the MOSs associated with mean  consumption  values are between
200 and 500.  The MOSs  for consumption  of  1 or 2 ears of corn
on the cob are lower, varying  from 39  to 77 for  the  general
population and 13 to 26 for children.   Finally,  for  fresh
whole tomatoes, the MOSs for  the general population  range
from 25 to 125, for adult males  from 25 to 143,  for  adult
females from 25 to  111, and for  children from 25 to  143,
depending upon the daily consumption of  tomatoes.  For  these
population groups, the MOSs based on mean  consumption levels
are between 111 and 143. The MOSs for these populations  would
decrease proportionally if corn  and  tomatoes  were  eaten in
large amounts on the same day.

     Non-dietary Risk Assessments (application and reentry)

     Applicators and mixer/loaders are  exposed to  EPN during
their work activities.  Field  workers are also exposed when
entering areas treated with EPN.  Typical  activities  of  field
workers include weeding and scouting.

     The NOEL used was  0.01 mg/kg/day  for  spinal histopathological
effects seen in the Huntingdon Laboratories 90-day oral  feeding
study in hens (DAS 2181637, Mar. 3,  1982) which  assessed the
effects from subchronic exposure to  EPN.  However, applicators,
mixer/loaders, and reentry workers are  primarily acutely exposed;
they are not subjected to subchronic exposures over  90  days.
The Agency used this study to  calculate a NOEL because  the
study represented the best data available for  human  risk
assessment purposes.  The Agency is  requesting an  acute
delayed neurotoxicity study to determine a NOEL  for  spinal
histopathological effects from a single  acute exposure to
EPN.  When this study is received and evaluated  by the  Agency,
a new NOEL will be determined  and a  new risk  assessment for
acute exposure to humans will be calculated.

     Based on average exposure values from surrogate pesticide
studies, in which mixer/loaders wore gloves and  typical  work
clothing, and applicators only wore  typical work clothing,
MOSs were'calculated for work  activities for  cotton,  soybeans,
and field corn.  MOSs for mixers/loaders for  cotton,  soybeans,

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                             -34-

Table 6 - Tolerance Assessment System Analyses for Dietary Exposure
          and Margins of Safety Calculations
1.  Fresh Cooked Corn, including fresh, corn on the cob, canned
    and frozen, containing 0.1 ppm EPN with no reduction of residues
    from cooking.
                              Fresh Cooked Corn Consumption
                         Mean  	   95th percentile   99th percentile
U.S. Population     0.00002
    (MOS)             (500)
Children l-6yr      0.00005
    (MOS)             (200)
Children 7-12yr     0.00004
    (MOS)  .           (250)
                                     mg EPN/kg  bw/d

                                       0.0001
                                        (100)
                                       0.0002
                                          (50)
                                       0.0002
                                          (50)
                       0
           ,0002
            (50)
           ,0004
            (25)
           ,0003
            (33)
    Corn on the Cob only, containing 77 gm/ear, 0.1 ppm EPN,
    and no reduction of residues from cooking.  TAS does not single
    out corn on the cob but  includes it with  fresh corn.   It  is
    unique because (1) it is frequently consumed at relatively
    large quantities and/or  for many consecutive days during  the
    fresh market season,  (2) it does not undergo the processing of
    canned or frozen corn, and (3) therefore  the TAS analysis may
    be an underestimation of exposure.

                             Corn on the Cob Consumption
                                 1 Ear        2 Ears
                                   mg EPN/kg  bw/d
            U.S. Population
                 (MOS)
            Children
                 (MOS)
0.00013
  (77)
0.00039
  (26)
0.00026
  (39)
0.00078
  (13)
    Fresh Whole Tomatoes containing 0.3 ppm  EPN.  During the fresh
    market  season  an  individual may eat relatively large quantities
    and/or  for many consecutive days.

                                    Tomato Consumption
                                  Mean	95th percentile
                                       mg  EPN/kg  bw/d
            U.S. Population
                 (MOS)
            Males 20+
                 (MOS)
            Females 20+
                 (MOS)
            Children 1-12  yr
                 (MOS)
 ,00008
  (125)
 ,00007
  (143)
 ,00009
  (111)
 ,00007
  (143)
0.0003-0.0004
   (33-25)
0.0003-0.0004
   (33-25)
   0.0004
     (25)
0.0003-0.0004
   (33-25)

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                              -35-

and field corn ranged  from  0.003 for  cotton  to  0.5 for field
corn.  The  daily  MOS for  applicators  for these  crops ranged
from 0.05 for cotton to 1.4  for field corn (Table  7).   In  the
absence  of  a dermal absorption  study  dermal  absorption was
assumed  to  be 31% based on a  comparison  of oral  and  dermal
LD5Q values, the  best  data  on the  subject  currently  available.
The MOS  is  calculated  on  a  daily basis because  it  is an acute
exposure scenario.

     The MOSs for field workers not wearing  protective clothing
were calculated for five  crops  (soybeans, cotton,  corn,  pecans,
and citrus) based on dislodgeable  residue  dissipation  data for
EPN (Table  8).  MOSs for  one  hour  exposure were  under  100  for
all crops even several days  after  application.   For  example,
for cotton  the MOS is 30  for  7 days after application  and  did
not exceed  100 until 8-14 days  after  application.  For soybeans,
corn, and pecans the MOSs are 30 after 2 days, and did not
exceed 100  until 2-5 days  after  application.   For  citrus the
MOS is 30 even at 35 days after application.  Currently  the
Federally established  reentry interval is 24 hours (40 CFR 170.3
                   C.  ENVIRONMENTAL PROFILE

1.  Ecological Effects.

     Existing data are adequate to show that EPN is highly
toxic to honey bees (Atkins et al. , 1975).  The LCso was
0.245 micrograms (ug) per bee (highly toxic).  As such, labels
of end-use EPN products  intended for foliar application must
contain a bee precaution statement.

     Existing data are adequate to show that technical EPN is
very highly toxic to freshwater fish species, freshwater
invertebrates, and estuarine/marine organisms.   Short term
fish bioassays with technical EPN show 96-hour LCso values
for rainbow and bluegill to be 80 and 190 ug/1, respectively
(Union Carbide, 1976).  Short term freshwater invertebrate
acute studies with technical EPN show 48-hour LCso values for
Daphnia magna to be 0.32 ug/1 (Union Carbide, 1976) and
36.0 ug/1 for Gammarus lacustris (Sanders, 1969).  Short term
marine invertebrate studies of EPN show 96-hour LCso values
ranging from 4.6 ug/1 for Penaeus Stylirostris to 13 ug/1 for
Mysidopsis bahia (U.S. EPA, 1981).   The 96-hour iJCso values
ranged from 37 ug/1 for spot to 140 ug/1 for sheepshead in a
short term marine fish study of EPN (U.S.  EPA,  1981).   Eastern
oyster larvae with a 48-hour ECso value of 2200 ug/1 were much
less sensitive than either the fish or invertebrate species
tested (U.S.  EPA, 1981).

     Two EPN formulated products,  Budmor 42 (containing
20.94% EPN, 41.86% methyl parathion and 26.67% xylene) and a

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                                 -36-
Table 7 - Average Applicator Exposure and  MOS  to EPN1

Crop

Cotton




Expos lire
Type2
Aerial
Loading closed
open
Application
Total
Expos xore
mg/kg/day

0.3
12
0.04

Days
Exposed

2
2
2

MOS3
(daily)

0.1
0.003
0.7
Soybeans
 Field
 Corn
Gr ound
  Loading
  Application
  Combined

Aerial
  Loading closed
          open
  Application

Gr ound
  Loading
  Application
  Combined

Aerial
  Loading closed
          open
  Application
                                     1.5
                                     0.6
                                     2.1
                                     0.1
                                     4.1
                                     0.03
                                     1.0
                                     0.3
                                     1.3
0.07
2.9
0.02
              7
              7
              7
              2
              2
              2
              2
              2
              2
1
1
1
         0.02
         0.05
         0.01
         0.3
         0.007
         1.00
         0.03
         0.10
         0.02
0.5
0.01
1.4
   Adapted  from R.  Zendzian.   Internal  memorandum entitled "EPN, Risk
   Assessment for Organophosphate Delayed Neurotoxicity, Applicator,
   Reentry  and Dietary"  Dated February  6, 1987.

   Based  on average exposure values from surrogate pesticide studies,
   mixers/  loaders wearing gloves and normal work clothes, and
   applicators wearing only normal work clothes.   Total exposure
   estimates amount of EPN reaching the skin, not absorbed dose.
    MOS  calculation  includes  an assumed dermal absorption rate of 31%.

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                                      -37-

Table 8 - Theoretical Risk to Scouts and Field Wbrkers Fran Exposure to
          Dislodaeable Residues after Treatment of Crops with EPN1
Exposed
Crop Population
(DTTON Scouts





SOYBEANS Sccuts




CORN Field
Wbrkers




PECANS Scouts






CITRUS5 Field
Workers







Days after
Application
0
1
2
5
7
14
0
1
2
5
7
0
1
2
5
7
14
0
1
2
5
7
14
21
0
1
2
5
7
14
21
28
35
Exposure^
(itiq/kq/hr )
0.065
0.029
0.015
0.006
0.003
0.0003
0.004
0.003
0.001
0.0001
0.00005
0.01
0.006
0.003
0.0003
0.0002
0.0001
0.01
0.002
0.001
0.0003
0.0002
0.0001
0.0001
0.179
0.097
0.079
0.064
0.041
0.023
0.012
0.010
0.001
MDS/hr
Exposure 6 4
0.55
1.00
1.98
5.00
30.00
300.00
7.50
10.50
30.00
300.00
600.00
3.00
5.00
10.00
100.00
150.00
300.00
3.00
15.00
30.00
100.00
150.00
300.00
300.00
0.20
0.30
0.40
0.50
0.70
1.30
2.50
3.00
30.00
   Adapted from R.  Zendzian.   Internal memorandum entitled "EPN, Risk Assessornt
   for Organcphosphate Delayed Neurotoxicity, Applicator, Reentry and Dietary"
   Dated February 6,  1987.
2  Assumes 60 kg body weicjit
3  Assures 31 percent dermal  absorption  based on a comparison of LE^QS of EPN by
   the oral and dental route.
4  The NOEL is 0.01 mg/kg/day  based  on the 90 day feeding study in hens showing
   histcpathological  effects in the  spinal cord.  The Agency will recalculate this
   NOEL upon receipt  and evaluation  of the required acute delayed neurotoxicity study,
5  Data on use of EPN on citrus gathered by the Agency indicate that EPN is not used
   on citrus in the United  States.   The  exposures and MOSs are presented here to show
   what the theoretical risks  would  be if EPN ware used on citrus, since it remains
   a currently registered use.

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                             -38-

wettable powder (containing 25% EPN) were tested in warmwater
fish and found to be hiqhly toxic.  The  96-hour LCso  for  bluegill
exposed to Budmor 42 is 650 ug/1 (001000091).  The 96-hour LCso
for fathead exposed to 25% wettable powder  is  200 uq/1  (Henderson
et al., 1959).

     Since mosquito larvicide uses of EPN have been cancelled  as
a result of the RPAR, contamination of water from the remaining
uses of EPN is most likely to occur from runoff.  Projected
residues of EPN in water resulting from  runoff cannot be
estimated by modeling, since chemical parameters necessary
for modeling are not available.  However, predicting  residues
in water from runoff without modeling, based on use rates
ranging from 0.25 to 1.0 Ib ai/A, results  in concentrations
of approximately 2.0 to 9.0 ug/1.  Predicting  residues  in
water from runoff after application to corn at application
rates of 0.25. to 0 5 Ib ai/A results  in  concentrations  of
approximately 6.0 to 12 ug/1.

     The LCso for fish  is  80 ug/1 and for  aquatic  invertebrates
is 0.32 ug/1.  Comparison  of these fish  and aquatic invertebrate
LC5QS to the above estimated residue  levels of 2.0 to 12.0 ug/1
suggests that non-target aquatic  invertebrates indigenous to
small ponds could be exposed to acutely  toxic concentrations of
EPN.  The Agency is requesting actual and simulated field
testing to assess more specifically potential  adverse effects
to non-target aquatic species.

     Based on the mysid shrimp and sheepshead  minnows Maximum
Acceptable Toxicant Concentration (MATC) of 0.44 to 3.4 and
0.88 to 2.2 ug/1 respectively, chronic effects may be expected
at the  concentrations estimated above 2.0 to 12.0 ug/1.
However, the chronic tests with mysid shrimp and sheepshead
minnows demonstrated' that  effects occurred  during the later
stages  of exposure; thus chronic effects may be unlikely  if
EPN occurs intermittently.  Although EPN is mildly biocon-
centrated, it is also rapidly depurated  (eliminated from  the
animal's body).  Significant accumulation  is unlikely unless
EPN is  present continuously.  Acute toxicity of EPN is  possibly
the greatest hazard.  The Agency  is requiring  an aquatic
residue monitoring study or a mesocosm study in order to
better  estimate environmental contamination and to complete
the assessment of the persistence of  EPN relative to  its
chronic toxicity or bioaccumulation potential.

     In addition to the above aquatic study, the Agency has
 identified the following areas as data gaps for EPN:

         0 A fish early life-stage study.  This study is
           required to  support registration of an  end-use
           product that is expected to be transported to
           water from the  intended use site, when  certain
           conditions apply:

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                             -39-

               - Any EC5Q or LCso value  in  acute  tests is
                 less  than  1 mg/1 .   (The  blueqill LCso with
                 an  80% EPN formulation was 0.08  mg/1).

               - The estimated environmental concentration
                 (EEC) in water  is equal  to or  greater than
                 0.01  of any ECso or ££50 from  acute testing.
                 (The  EEC from runoff  is  2.0 to 12.0 ug/1 ,
                 which is approximately 2 to 15 times  higher
                 than  0.01 of the bluegill  LCso of  80  ug/1).

               - The EEC is less than  0.01  of the ECso or
                 LCso  values but the pesticide  is persistent
                 in water.  (The persistence of EPN in water
                 has not been adequately defined).

           The Agency  expects that aquatic  environments will be
           exposed from use on cotton therefore a fish early
           life-stage  study is required.

           An aquatic  invertebrate life-cycle study.  This
           study is required to support the registration of
           any end-use product that  is expected to be trans-
           ported to water from the  intended use site,  when
           certain conditions apply:
               - Any ECso or LCso value in acute tests is less
                 than 1 mg/1.  (The daphnid LCso with a 99% EPN
                 formulation was 0.32 mg/1).

               - The estimated environmental concentration
                 (EEC) in water is equal to or greater than
                 0.01 of any ECso or ^50 from acute testing.
                 (The EEC from runoff is 2.0 to 12.0 ug/1,
                 which is approximately 625 to 3750 times  higher
                 than 0.01 of the daphnid LCso of °-32 ug/1).

               - The EEC is less than 0.01 of the ECso or
                 LCsO values but the pesticide is persistent
                 in water.  (The persistence of EPN in water
                 has not been adequately defined).

           The Agency expects that aquatic environments will be
           exposed from use on cotton.   Therefore,  an aquatic
           invertebrate life-cycle study is required.

     Existing data are also adequate to show that technical
EPN is very highly toxic to waterfowl,  upland game  birds  and
passerine birds.   The 8-day dietary  studies conducted with
technical EPN show dietary LCso values  for waterfowl (mallard
ducks) and upland game birds (bobwhite  quail)  to be 168 ppm and
349 ppm, respectively (Hill et al.,  1975).   Avian acute oral
studies have demonstrated LDgQ values of 7.09 mg/kg (Hudson

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                             -40-

et al., 1979) and 27 mg/kg (Fink, 1976) for waterfowl  (mallard
ducks).  Avian oral LDso values for upland garre birds  were
shown to be 53.4 mg/kg for ring-necked pheasants  and 5.25 mg/kg
for coturnix (Tucker and Haegele, 1971).  The 24-hour  percutaneous
LC^o for mallard ducks was determined to  be 400 mg/kg  (Hudson
et al. , 1979) .

     Acute oral exposure is perhaps the principal  route  of
pesticide uptake for outdoor application  of granular formula-
tions, principally  through the accidental  ingestion of granules
adhering to food or left on the soil surface either from
incomplete incorporation or spillage.  Dietary exposure  is
the principal route for emulsifiable concentrate and wettable
powder formulations.  With a 24-hour percutaneous  LDso value of
400 mg/kg, EPN does not appear to present a dermal hazard.

     The risk posed by consuming EPN granules to seven species
of birds known to utilize cultivated fields is shown in Table 9.
For small birds that forage for food and  grit on the soil
surface and that may pick up exposed granules, the number of
granules required to cause death may be an  important indicator
of potential hazards.  Although many factors may contribute
to actual hazards, the Agency believes that the number of EPN
granules required to cause death is large  and demonstrates a
wide margin of safety.  In a 1984 study,  Balcomb et al.
(Bull. Environ. Contam. Toxicol. 33:302-307;  1984) reported
that an EPN 4% granular formulation caused no mortality at
doses  up to 20 granules in house sparrows  and 40  granules in
red-winged blackbirds, confirming the Agency's predictions.

     Kenaga, in a 1973 study (Environmental Quality and
Safety; Vol. II; 1973; pp 166-181) reported that  direct
application of EPN  emulsifiable concentrate and wettable
powder formulations to croplands at 0.25  to 1.0 lb. a i/A
would be expected to produce upper limit  (maximum) initial
residues over  that  application range of 1.75  to 7  ppm  on
fruits, 14.5 to 58 ppm on forage, 31 to 125 ppm on leaves and
leafy  crops, 27 to  110 ppm on  long grasses  and 60  to 240 ppm
on short ra^qegrass.  More typical limit  (average) estimates
are 0.37 to  1.5 ppm on fruits, 8.25 to 33 pom on  forage, 8.75
to 35 ppm on leaves and leafy crops, 23 to  92 ppm  on long
grasses and  31 to 125 ppm on short rangegrass.  These  typical
residues exceed restricted use criteria (40 CFR 162.11 (c)(l)
(iii)(B) and 40 CFR 162.11 (c)(2)(iii)(B))  (1/5 LC50 for
upland game birds of 349 ppm = 69.8 ppm)  on certain avian
food  items at  the higher rates of 1.0 lb. ai/A.   EPN is
already a restricted use pesticide.

     In a 1984 study (Toxicol. Appl. Pharmacol. 73:284-294;
1984), Hoffman and  Sileo examined the effects of  topical
applications of EPN on mallard eggs for potential  embryonic,
teratogenic and neurotoxic effects.  Mallard  eggs  were topically
treated at 72  hours of  incubation with 56%  EPN at  concentrations

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                             -41-
Table 9.  Hazard to Seven Species of Non-Target  Birds  from
          2% and 4% Granular EPN Formulations
Number of Granules equal
to LD^n1
Species
Mallard
(14-day)
Mallard
(adult)
Robin2
Mourning Dove2
House Sparrow2
Redwing
Blackbird
Grasshopper
Sparrow^2
Attwa ter1 s
Body
we igh t
(q)
200

1200

80
100
20
50
13.9
1000
mg/
animals
(q)
0.20

1.20

0.08
0.10
0.02
0.05
0.01
1.00
2G
Granules
3375

20250

160
200
40
100
20
16875
4G
Granules
1687

10125

80
100
20
50
10
8437
Prairie Chicken-^
(adult)

(14-day)
50
0.05
843
422
1  Weight of one granule = 0.08 mg (Balcomb et al.f 1984).

    - mg a. i.  2% granule = 0.08 mg X 2% =  0.0016 mg EPN/granule.
    - mg a.i.  4% granule = 0.08 mg X 4% =  0.0032 mg EPN/granule.
    -.Mallard LD^Q X Weight (kg)        = 27.0 mg/kg X 0.200 kg
                                        =  5.4 mg/animal.
      The number of 4% granules
      required to equal Mallard
      LD5Q
                              5.4  kg
                        0.0032 mg a.i./granule

                     =  1687 granules  equivalent
                        to  mallard LD5Q
2  Assuming equal sensitivity as the redwing blackbird; 3.2 mg/kg,
   as reported by Schafer in 1972.

3  Assuming equal sensitivity as the mallard;  27 mg/kg as reported
   by Fink in 1976.

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                             -42-

of 0.25 Ib/gallon (gal), 0.75 Ib/gal and 1.25  Ib/gal.  The  study
reported that external treatment of mallard eggs with EPN at the
field level of application (0.25 Ib/gal) was both  embryotoxic
(22 to 44% mortality over the dose range) and  teratogenic (37
to 42% of the surviving embryos at 18 days were  abnormal with
cervical and axial scoliosis as well as severe edema).  Brain
development was also impaired as reflected by  significantly
(p < 0.05) lower brain weight in hatchlings when compared to
controls.  Body weight did not differ significantly.  Neurotoxic
effects were observed throughout embryonic development and  in
hatchlings as manifested by lower brain acetylcholinesterase
(AChE) and brain neurotoxic esterase activity.  Although this
is a  scientifically sound study, mallard eggs  were treated
with  EPN under laboratory conditions and may not reflect
actual field conditions.  As noted in Table Af the Agency
will request'actual and simulated field studies in  avian
species after receipt and review of environmental  fate
studies and an avian reproduction study.

      Laboratory data indicate that EPN is very highly acutely
toxic to avian species.  Estimated exposure on one  of the
vegetative groups listed above (short rangegrasses, potential
food  sources that have large surface area to mass  ratios) is
of particular concern.  Additionally, topical  treatment to
mallard eggs resulted in embryotoxicity, neurotoxicity and
teratogenicity, under laboratory conditions.   Many  factors
can contribute to different results under field conditions.
Therefore, the Agency is requiring an avian reproduction
study especially in light of the fact that there are repeat
applications of EPN to cotton.

2.  Endangered Species.

       Based on the Agency's analysis, it appears  that certain
use patterns of EPN may result in sufficient exposure to pose
a potential hazard to certain endangered/threatened species
of mammals, birds, aquatic organisms, crustaceans,  reptiles
and insects.  (See Regulatory Position #7 in Section IV below.)

3.  Environmental Fate.

      The available data are  insufficient for the Agency to
fully assess the environmental fate and transport  of EPN and
the potential exposure of humans and nontarget organisms to
EPN.  However, available preliminary information that does not
meet  the Agency's data requirements does indicate  general trends
of EPN behavior in the environment.  EPN degrades  in aerobic
sandy loam soil with a half-life of 4 to 8 weeks.   Phenylphos-
phonic acid, O-ethyl phenylphosphonic acid, and O-ethyl phenyl-
phosphonothioic acid are expected to be the main degradates
under aerobic conditions.  In the field, EPN dissipates with a
half-life of 2 to 8 weeks from silt loam soils in  Delaware  and

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                             -43-

Mississippi.  EPN was detected  in tailwater pit  sediments  and
water  in Kansas  in  1974.   EPN accumulates  in  pinfish tissue
700 fold and sheepshead minnow  tissues  10,000  fold.  Rapid
depuration was noted  in pinfish.

     To assess the environmental fate of EPN  in  conjunction
with its terrestrial  food  crop  and terrestrial nonfood  use
patterns, the Agency is requiring the following  studies:

     Hydrolysis
     Photodeqradation on soil
     Photodegradation in water
     Aerobic soil metabolism
     Anaerobic soil metabolism
     Leaching and adsorption/desorption
     Soil dissipation
     Long-term soil dissipation
     Rotational crops (confined and field)
     Fish accumulation.

     In addition, a special Droplet Size Spectrum and Spray
Drift Field Evaluation Testing  is being required due to the
toxicity of EPN, its methods of application, and the likely
exposure of off-site people and wildlife to the pesticide.
The droplet spectrum study is to be performed to reflect the
nozzle and other equipment types to be used in the application
of EPN.  The spray drift field  evaluation  is to  be performed
to reflect the application equipment, use patterns, and
typical locations of use,  which include different weather
factors, in the application of  EPN.
                   D.  TOLERANCE REASSESSMENT

     Tolerances have been established for residues of EPN in
a variety of raw agricultural commodities (40 CFR 180.119).
Most of the tolerances were established with little or no
data in conjunction with the pesticide "Spray Residue Hearings"
of the late 1960s.  EPA has evaluated the available residue
chemistry and toxicology data and has determined that a full
tolerance reassessment for EPN can not be made at this time
because of extensive data gaps.   However, the Agency has
conducted an assessment of the tolerances relative to dietary
exposure and the estimated risk of the delayed neurotoxic
effect.  Dis-ussion of this is provided in subsection B,
above.  Since most of the required toxicology studies are
missing and additional data are  required in order to more
precisely estimate dietary exposure and its toxicological
significance, no new tolerances, either group or otherwise,
will be established.  The residue and toxicology data with
regard to EPN tolerances are discussed in the following
subsections.

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                             -44-

1.  Residue Data.

     Nature of Residues in Plants.

     The metabolism of EPN in plants is not adequately
understood.  Detailed characterization of  residues  in whole,
10-week old cotton plants has revealed the presence of  EPN
and two metabolites, O-ethyl phenylphosphonic  acid  and
phenylphosphonic acid.  The latter compound was found only
in bound form.  This study also  revealed that  14C-residues
of [I^CJEPN are absorbed into plant tissues following foliar
applications.  No  studies have been submitted  that  elucidate
the nature of EPN residues in cottonseed (the  raw agricultural
commodity  processed for human consumption) or  in  any other
crops on which registered use of  EPN exists.   The following
data are required:

     0  Plant metabolism studies  reflecting the distribution
        and metabolis" of benzene ring-labeled [l^ClEPN in:

             1)  mature cottonseed harvested 3 days
                 after several foliar applications  at
                 1  Ib ai/A made  4 to 5 days apart;

             2)  field corn fodder and mature  field
                 corn grain harvested 14 days  after
                 several applications at 0.5 Ib ai/A
                 made 5 days apart; and

             3)  mature pecans harvested 21 days
                 following the last of several foliar
                 applications at 7-day intervals  at
                 3.5 Ib ai/A.

        The  rates  stated here are based on maximum  registered
        rates; exaggerated rates  may be necessary to obtain
        sufficient residues in the harvested plant  portion for
        characterization.  Analyses should include  hydrolysis
        and  reextraction of plant residues and aqueous  extracts
        to determine conjugated  -^C-residues of EPN.  If metabolism
        results  differ significantly among the three crops, then
        additional  metabolism data must be submitted for a
        representative crop in each crop group for  which
        registered uses of EPN exists.

     Tolerances  for EPN residues in or on  plant comodities are
 currently  expressed in terms of  parent only.   If the data
 required above  indicate additional residues of toxicological
concern, the tolerance definition will be  changed accordingly.
 (The registrant  should conduct the required metabolism  studies
 and should submit  them to the Agency for review prior to
 conducting the  field studies described below under  "Magnitude
 of Residues  in Plants.")

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                             -45-

     Nature of Residues in Animals.

     No tolerances presently exist  for  residues of  EPN in
animal products.  However/ the submitted  data  pertaining to
the metabolism of EPN in  animals indicate that EPN  residues
will transfer to tissues  of poultry,  but  otherwise  are
inadequate to show the nature of those  residues in  poultry
or other animals.  The nature of EPN  residues  in animals  is
therefore not adequately  understood.  The following data
are required:

     0  Metabolism studies utilizing  ruminants.
        In these studies the animals  must be dosed  for
        three days with ring-labeled  [14C]EPN  at a
        concentration in the total diet which  will
        result in sufficient residue  in the tissues
        and milk for characterization.  Animals must
        be sacrificed within 24 hours of  the final
        dose (milk must be collected  twice daily).
        14C-Residues must be characterized and
        quantified in milk, muscle, fat,  kidney, and
        liver.  If residues of toxicological concern
        are found to transfer to the  tissues and/or
        milk of ruminants, appropriate tolerances
        must be proposed.

     0  Metabolism studies utilizing poultry.
        In these studies  the animals must be dosed  for
        three days with ring-labeled  [14C]EPN at a
        concentration in the total diet which will
        result in sufficient residue  in the tissues
        and eggs for characterization.  Animals must
        be sacrificed within 24 hours of  the final
        dose (eggs must be collected twice daily).
        l^c-Residues must be characterized and
        quantified in eggs, muscle, fat,  kidney, and
        liver.  If residues of toxicological concern
        are found to transfer to the  tissues and/or
        eggs  of poultry, appropriate tolerances must
        be proposed.

        Furthermore, if the nature of the residue in
        poultry differs significantly from that in
        ruminants, additional data depicting the nature
        of the residue in swine will be required (i.e.
        in the absence of rat metabolism data).  If
        poultry and  ruminant metabolism differ from
        that in the rat then additional swine data  are
        required.

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                             -46-

     Residue analytical methods.

     Adequate methods are available for collection of data
pertaining to residues of EPN in plant commodities.  These
methods are based on nitrophenyl detection through colorimetry,
and detection by gas chromatography.  These methods have not
been assigned company designations.  However, the colorimetric
procedure is usually referred to as "The Parathion Method"
(E.I. du Pont de Nemours & Co./ Inc., 1949) Another colorimetric
method, commonly referred to as the "Total Phosphorus Method"
(E.I. du Pont de Nemours & Co., Inc., 1949) cannot be assessed
due to the absence of any recovery data.  However, since no
residue data generated using this method may be used to
support established tolerances, due to inadequacies unrelated
to the analytical method, the Agency does not require validation
data for this method.  The Agency recommends that the GC method
(E.I. du Pont de Nemours & Co., Inc., 1977) be used in the
future for data collection.

     The colorimetric methods are nonspecific and therefore
not suitable for enforcement work.  Also, the GC method
(E.I. du Pont de Nemours & Co., Inc., 1977) may not be used
for enforcement purposes because no confirmatory procedure
has been included in the method discussion.  However, two
multiple-residue enforcement methods for EPN determination
are  listed in the PAM Volume II, Pesticide Regulation Section
180.119.  Both involve organic solvent extraction and GC
detection.

     It  should be noted that the nature of residues in plants
is not adequately understood.  If the metabolism data requested
above  reveal additional residues of toxicological concern,
additional methods for tolerance enforcement and data collection
will be  required.

     Storage Stability.

     No  data have been submitted regarding the stability of
EPN residues in or on plant samples in frozen storage.  The
following data are required:

     0  Storage conditions and harvest-to-analysis intervals
        studies.

        These studies must be submitted for  the samples of corn
        grain, sweet corn, tomatoes, cottonseed, and soybeans
        from which residue data were collected and used to
        support established tolerances for residues in or on
        corn, tomatoes, beans (dried), and cottonseed.  Data
        reflecting the storage stability of EPN in plant
        samples at the intervals specified must be submitted.
        If storage stability is poor, conclusions regarding
        the adequacy of tolerances  for residues in or on these
        commodities may change.

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                              -47-

      0  Data  on the  conditions  and  intervals  of  sample storage
        including  fortification  and  recovery  data.

      0  All residue  data  required  in this standard  must be
        accompanied  by  information pertaining  to  the  conditions
        and intervals of  sample  storage  as well  as  fortification
        and recovery data reflecting the  stability  of EPN at
        such  intervals.

      It should  be  noted that  the nature  of  the residue in plants
is not understood.   If  the requested plant metabolism data
reveal additional  metabolites of  toxicological concern, data
reflecting the  stability  of these metabolites  in  frozen storage
will  be required.  Also,  if residues of  concern  transfer  to
livestock, data depic4-'  q the stability  of  EPN and  metabolites
of concern in animal products will be required.

      Magnitude  of  the Residue in Plants

      Root and Tuber  Vegetables Group

      A crop group  tolerance is not appropriate at this time
for the following  reasons:

      0  Data  are required to  support the  established  tolerances
        for EPN residues in or on sugar beets, a representative
        crop.

      0  Residue data are  required for  three additional represen-
        tative crops:  carrots, radishes, and  potatoes.   (If the
        registrant/petitioner proposes a  use and submits  residue
        data in support of the tolerances  for  residues in or on
        beets and  turnips, no data are required for carrots and
        radishes.)

          Beets, Rutabagas, and Turnips

     There are  currently no registered uses of EPN on beets,
rutabagas, and  turnips.   However, a  tolerance  of 3 ppm has  been
established for residues of EPN in or on beets (with or without
tops), rutabagas (with  or without tops), and turnips  (with  or
without tops).  Since EPN has  no registered use on beets,
rutabagas, and  turnips,  the Agency will  revoke the currently
established tolerance for residues of EPN in or on these crops
unless the registrant proposes a use  and submits appropriate
residue date  in support  of the established tolerances.

     There are  no Canadian or Mexican tolerance,  nor  are
there Codex Maximum Residue Levels (MRL) for residues of  EPN
in or on beets,  rutabagas, arid turnips.

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                             -48-

          Sugar beets

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations of EPN are registered for an unspecified number
of foliar applications at 1 Ib ai/A using aerial equipment.
A 21-day Post Harvest Interval (PHI) is in effect.  Use of
ultra-low volume (ULV) application equipment  is permitted.
Although EPN is registered for use on sugar beets, no residue
data have been submitted in support of the established tolerance
for residues of EPN in or on sugar beets (without tops), and no
appropriate translatable data for other crops exists.  Therefore,
the following data are required to support the established
tolerance:

     0  Residue data  from sugar beet roots taken 21 days
        following the last of several foliar applications
        with a registered emulsifiable concentrate formula-
        tion of EPN at 1 Ib ai/A, using ground and aerial
        equipment, including ULV equipment in separate tests.
        The residue tests should take place in California,
        Idaho,  Minnesota, and North Dakota, which collectively
        account for approximately 67% of the United States
        sugar beet production.

     0  Data reflecting residues of EPN in dehydrated pulp,
        molasses, and refined sugar processed from sugar beets
        bearing measurable weathered residues.  If residues
        concentrate in any of these processed products,
        appropriate food/feed additive tolerances must be
        proposed.

     There  is no Canadian or Mexican tolerance, nor  is there a
Codex MRL for residues of EPN in or on sugar beets

     Leaves of Root and Tuber Vegetables Group

     A crop group tolerance is not appropriate at this time
for the following reasons:

     0  EPN presently has no registered use on turnips,
        a representative crop.  Should a use be proposed,
        appropriate residue data must be submitted.

     0  Residue data and a tolerance proposal are required
        for one other representative crop:  sugar beet tops.

          Beet Tops (greens), Rutabaga Tops, and Turnip
          Tops (greens).

     There  are currently no registered uses of EPN on beets,
rutabagas, and turnips.  However, a tolerance of 3 ppm has been
established for residues of EPN in or on beet greens, rutabagas
tops, and turnips greens.  Since EPN has no registered use on

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                             -49-

beets, rutabagas, and turnips, the Agency will revoke the
currently established tolerance for residues of EPN in  or  on
beets greens, rutabaga tops (tops are not presently considered
to be a raw agricultural commodity of rutabagas), and turnip
greens unless the registrant proposes a use and submits appropriate
residue date in support of the established tolerances.

     There are no Canadian or Mexican tolerances, nor are
there Codex Maximum Residue Levels (MRL) for residues of EPN
in or on beet greens, rutabagas tops, and turnips greens.

          Sugar Beet Tops

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations of EPN are registered for an unspecified number
of foliar applications at 1 Ib ai/A using ground or aerial
equipment.  A 21-day Post Harvest Interval (PHI) is in effect.
Use of ultra-low volume (ULV)  application equipment is permitted.
Although EPN is registered for use on sugar beets, no tolerance
has been established for residues of EPN in or on sugar beet
tops at the present time.

     Since sugar beet tops are a raw agricultural commodity of
of sugar beets, residue data and a tolerance  proposal or feeding
and grazing restrictions must be proposed.  Therefore,  the
following is required:

     0  Residue data from sugar beet tops harvested at
        regular intervals  following the  last  of several
        applications with a registered EPN emulsifiable
        concentrate formulation at 1 Ib ai/A,  using ground
        and aerial equipment,  including  ULV equipment  in
        separate tests.   The residue tests should take place
        in California, Idaho,  Minnesota, and  North Dakota.
        A tolerance and a pregrazing interval  must be proposed;
        alternatively, feeding and grazing restrictions  may be
        proposed.

    .There is no Canadian or Mexican tolerance,  nor is there
a Codex MRL for residues of EPN in or  on sugar  beets.

     Leafy Vegetables (except  Brassica Vegetables) Group

     A crop group  tolerance  is  not appropriate  at  this time
for the following  reasons:

     0  Data are required  to support the established
        tolerances for residues of EPN in or on spinach
        and lettuce.   There is presently no registered
        use"of EPN on spinach.

     0  Data are required  on one other representative
        crop:   celery.

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                             -50-

          Lettuce

     The 4 Ib/gal emulsifiable concentrate formulations, of EPN
is registered in California (intrastate registration) for an
unspecified number of broadcast applications at 1 Ib ai/A using
ground or aerial equipment.  A 21-day PHI is in effect.  A
tolerance of 3 ppm has been established for residues of EPN
in or on lettuce.

     No residue data have been submitted in support of  the
established tolerance for residues of EPN in or on lettuce,
nor are appropriate translatable data available.  The following
data are required to support the established tolerance:

     0  Residue data from mature leaf and head lettuce,
        harvested 21 days after the last of several foliar
        treatments of the 4 Ib/gal EPN emulsifiable
        concentrate formulation at 1 Ib ai/A;  aerial
        and ground applications should be represented
        in separate tests.  The tests must take place
        in California, the only state in which EPN is
        registered for use on lettuce.

     There is no Canadian tolerance nor is there a Codex MRL
for residues of EPN in or on lettuce.  A Mexican tolerance
of 3 ppm has been established for the residues of EPN in or
on lettuce.

          Spinach

     There are  currently no registered uses of EPN on spinach.
However, a tolerance of 3 ppm has been established for residues
of EPN in or on spinach.  Since EPN has no registered use on
spinach, the Agency will revoke the currently established
tolerance for residues of EPN in or on this crop unless
the registrant  proposes a use and submits appropriate residue
data  in support  of the established tolerance.

     There is no Canadian tolerance nor is there a Codex MRL
for residues of EPN in or on spinach.  A Mexican tolerance
of 3 ppm has been established for the residues of EPN in or
on spinach.

      Legume Vegetables Group

     A crop group tolerance is not appropriate at this  time
for the followina reasons:

      0  Data are required for Pisum varieties (both succulent
        and dried).

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                              -51-

      0  Additional  data are required  to support the established
        tolerances  for  residues  of  EPN  in or  on beans,  including
        dried  beans.

      0  Additional  data are required  to support the established
        tolerance for residues of EPN in or on  soybeans.

      0  The  established tolerance of  3  ppm for  residues of EPN
        in or on beans  is more than five times  greater  than the
        established  tolerance of 0.05 ppm for residues  of  EPN
        in or on soybeans.   If the  data requirements  outlined
        above  for peas  and  beans are  metf it  may be possible
        to propose a crop group  tolerance for legume  vegetables,
        excluding soybeans.

          Beans

      The 4 Ib/gal emuls if iable concentrate formulation  of  EPN
is registered  for an unspecified number of foliar applications
at 0.5 lb ai/A.  Two to four  foliar applications at 5-  to  7-day
intervals, may be made  at 0.125  to  0.5  lb ai/A  with the EPN
25% wet table powder  formulation  or  the  4 Ib/gal and 5 Ib/gal
emulsifiable concentrate formulations.  There is also an
intrastate product  for  use  in Alabama,  Arkansas, Georgia,
Louisiana, Mississippi, Tennessee, and Texas  which  permits
use of a 3 Ib/gal multiple  active ingredient  (EPN and methyl
parathion) emulsifiable concentrate on beans  (dry,  green,
and lima) at 1.5 lb  ai/A.   The emulsifiable concentrate
formulations may be applied  by aerial equipment.  The
emulsifiable concentrate formulations may also  be applied
using ULV equipment.  A 21-day PHI is in effect.  A tolerance
of 3 ppm has been established for residues of EPN in or on
beans.

     No residue data have been submitted in support of  the
established tolerance for EPN residues in or on beans.  The
Agency recommends that  separate  tolerances be established  for
residues of EPN in or on lima beans, snap beans, and dry beans.
The available soybean data  provide  adequate support for the
3 ppm "bean" tolerance  for residues of EPN in or on dry beans.
However, if a crop group tolerance  is desired,  additional  data
must be submitted for dry beans since data translated from
soybeans, a representative  commodity of the Lequme  Vegetables
Group, cannot be used to satisfy the data requirements  for
dried beans, which is also a  representative commodity.  Data
are required to support the 3 ppm tolerance for EPN residues
in or on snap beans and lima  beans.   The data requested below
for snap beans will be translated to lima beans.  The following
data are required:

      0  Residue data from mature snap beans harvested 21 days
        following several foliar applications of the 3  Ib/gal
        emulsifiable concentrate formulation, at 1.5 lb ai/A.

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                             -52-

        Separate tests must be run for both aerial and ground
        applicationsf including separate tests for the use of
        ULV equipment.  The tests should take place  in Georgia,
        Tennessee, and Louisiana, representative states in
        which use of the high rate (1.5 Ib ai/A) is  permitted.
        Data may be translated from snap beans to lima beans
        to support a tolerance for residues of EPN in or on
        lima beans.

     0  Residue data from snap bean cannery residue, processed
        from snap beans bearing measurable, weathered residues.
        Exaggerated rates may be necessary to achieve such
        residue levels.  If residues are higher in cannery
        waste than in snap beans per se an appropriate feed
        additive tolerance must be proposed.

     There is no Canadian tolerance nor is there a Codex MRL
for residues of EPN in or on beans.  A Mexican tolerance of
3 ppm has been established for residues of EPN in or on beans.

          Soybeans

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations of EPN are registered for all necessary foliar
applications at 1 Ib ai/A.  Ground and aerial applications
may be made.  The use of ULV equipment is also permitted.  A
21-day PHI is in effect.  A tolerance of 0.05 ppm (negligible
residues) has been established for residues of EPN in or on
soybeans.

     The submitted data do not provide adequate support for
the established tolerance for residues of EPN in or  on soybeans
for the following reasons:  1) geographic representation is
poor; and 2) no aerial application data were submitted.  The
following additional data are required:

     0  Residue data from soybeans, harvested 21 days after
        the  last of several applications of an emulsifiable
        concentrate formulation of EPN at 1 Ib ai/A.  The data
        should reflect both aerial and ground applications,
        including separate tests for the use of ULV  equipment.
        The tests should be conducted in Illinois, Nebraska,
        Ohio, and Tennessee, which represent the major soybean
        production and climatic regions of the United States.

     0  Residue data  from two soybean processed commodities
        (hulls and soapstock).  These products must  be processed
        from mature soybeans bearing measurable, weathered
        residues of EPN.  Exaggerated rates may be necessary
        to achieve such initial residue levels.  If  residues
        are  found to concentrate in hulls and soapstock, an
        appropriate  feed additive  tolerance must be  proposed.

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                             -53-

     The available data  are  adequate  to  show  that  EPN  residues
will not concentrate in  soybean meal.  However, these  data  do
show that EPN residues will  concentrate  up  to 5.5  times  in
soybean oil.  Therefore/ the petitioner  must  propose a tolerance
for residues in soybean  oil  that  is approximately  6 times the
final accepted tolerance for EPN residues in  or on soybeans.

     There  is no Canadian  nor  is  there a Codex MRL for residues
of EPN in or on soybeans.  A Mexican  tolerance of  0.05 ppm
(negligible residues) has  been established  for the residues of
EPN in or on soybeans.

     Foliage of the Legume Vegetables Group

     A crop group tolerance is not appropriate at this time
for the following reason:

     0  Data are required  for the representative commodities,
        bean vines and hay (any Phaseolus sp.), field pea vines
        and straw (Pisum sp.  ) and soybean forage and straw.
        EPN is presently registered for use on soybeans and
        beans but no tolerances for residues  in or on forage,
        vines, hay, or straw have been established.

          Bean Vines and Hay

     The 4 Ib/gal emulsifiable concentrate  formulation of EPN
is registered for an unspecified number  of foliar applications
at 0.5 Ib ai/A.  Two to  four foliar applications at 5- to 7-day
intervals, may be made at  0.125 to 0.5 Ib ai/A with the EPN
25% wettable powder formulation or the 4 Ib/gal and 5 Ib/gal
emulsifiable concentrate formulations.  There is also an
intrastate product for use in Alabama, Arkansas,  Georgia,
Louisiana, Mississippi, Tennessee, and Texas  which permits
use of a 3 Ib/gal multiple active ingredient  (EPN and methyl
parathion) emulsifiable concentrate on beans  (dry, green,
and Lima) at 1.5 Ib ai/A.  The emulsifiable concentrate
formulations may be applied by both aerial and ground equipment.
The emulsifiable concentrate formulations may also be applied
using ULV equipment.  A 21-day PHI is in effect.   No tolerance
has been established or proposed for  residues of EPN in or  on
bean vines or hay.

     No residue data have  been submitted for  residues of EPN
in or on bean vines or hay.  The registrant must either
propose a feeding and grazing restriction for these commodities,
or submit tolerance proposals for residues of EPN in or on bean
hay and bean vines, a pregrazing interval for vines, and the
following supporting residue  data:

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                             -54-

     0  Residue data from bean vines and bean hay harvested
        after the last of several applications of the 3 Ib/gal
        EPN emuIsifiable concentrate formulation, at 1.5 Ib
        ai/A.  Tests must include both aerial and ground
        applications, including separate tests for the use of
        ULV equipment.  Vines must be sampled at  intervals
        following the last treatment and hay must be harvested
        21 days after the last treatment.  The tests should
        take place in Georgia, Tennessee, and Louisiana,
        representative states in which use of the high rate
        is permitted.  Tolerances for residues in or on bean
        vines and hay must be proposed and a pregrazing interval
        for bean vines must be proposed.  Alternatively, feeding
        and grazing restrictions may be proposed for bean vines
        and hay.

     There are no Canadian or Mexican tolerances  nor is there a
Codex MRL for residues of EPN in or on bean vines or hay.

          Soybeans

     The 4 Ib/gal and 5 Ib/gal enauls if iable concentrate
formulations of EPN are registered for all necessary foliar
applications at 1 Ib  ai/A.  Ground and aerial applications
may be made.  The use of ULV equipment is also permitted.
A 21-day prefceding and pregrazing interval is in effect.
A tolerance has neither been established nor proposed for
residues of EPN in  or on soybean forage or soybean straw.

     No data have been submitted for residues in or on soybean
forage or straw.  The registrant must submit tolerance proposals
for residues of EPN in or on soybean forage and soybean straw,
and the following data:

     0  Residue data  from soybean forage and straw , harvested
        21 days after the last of several applications of an
        EPN emulsifiable concentrate formulation  at 1 Ib ai/A.
        The data must reflect both aerial and ground applications,
        and must  include separate tests for use of ULV equipment.
        The tests should be conducted in Illinois, Nebraska,
        Ohio, and Tennessee.  Tolerances for residues of EPN
        in or on soybean forage and straw must be proposed.

     There  is no Canadian or Mexican tolerance nor is there a
Codex MRL for residues of EPN in or on soybean forage or soybean
straw .

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                              -55-

     Fruiting Vegetables  (Except Cucurbits) Group

     A crop group  tolerance  is  not  appropriate  at this time  for
the followina reason:

     0  Residue  data  are  required for  an  additional
        representative crop:  peppers.

          Tomatoes

     The 25% wettable powder  formulation  is registered  for
all necessary foliar applications at 7- to 10-day intervals
at 0.125 to 0.25 lb ai/A using  ground  equipment.  The  4 Ib/gal
and 5 Ib/gal emulsifiable concentrate  formulations are  registered
for all necessary foliar applications at 7- to 10-day intervals
at 0.25 to 1 lb  ai/A using aerial or ground equipment.   A 21
day PHI is in effect for these registrations.  In addition,
there is also an intrastate product registered for use  in
Alabama, Arkansas, Georgis, Louisianna, Mississippi, Tennessee,
and Texas that permits the use  of a 3  Ib/gal emulsifiable
concentrate multiple-active ingredient (EPN and methyl  parathion)
at 1 lb ai/A as  needed.  A 15-day PHI  is  in effect for  this
formulation.  The emulsifiable concentrate formulations may
be applied with  ULV equipment.  A tolerance of 3 ppm has been
established for residues of EPN in or on tomatoes.

     The submitted data are adequate to support the established
tolerance for the residues of EPN in or on tomatoes.  However,
the following data are required to determine whether food and/or
feed additive tolerances are needed for the processed products
of tomatoes:

     0  Residue  data from processed tomato products,  including
        wet pomace, dried pomace, puree, catsup and juice,
        processed from tomatoes bearing measurable, weathered
        residues of EPN.  Exaggerated application rates  may
        be necessary to achieve such initial residue levels.
        Should concentration of residues in processed products
       -occur, appropriate food and/or feed additive tolerances
        must be proposed.

     There is no Canadian tolerance nor is there a Codex MRL
for residues of  EPN in or on tomaotes.  A Mexican tolerance
of 3 ppm has been established for the residues of EPN in or
on tomatoes.

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                             -56-

     Citrus Fruits Group

     Citrus Fruit

     The 25% wettable powder formulation  is  registered  for
foliar applications at 0.75 to 3 Ib  ai/A or  0.25  to  0.5 Ib
ai/100 gallons using ground equipment.  The  4  Ib/gal  and
5 Ib/gal emulsifiable concentrate  formulations  are registered
for foliar applications at 0.5 to  2.25  Ib  ai/A  using  ground
or aerial equipment.  ULV applications  of  the  emulsifiable
concentrate formulations are also  permitted.  A 30-day  PHI
is in effect.  Treated rinds may not be used for  food or
feed.  However, the restriction prohibiting  the use  of  the
rind for food or feed in not practical  since the  disposition
of the citrus rind is not under the  control  of  the grower.
A tolerance of 3 ppm has been established  for residues  of EPN
in or on citrus fruit.

     The submitted data are not adequate  to  support  the
established tolerance for EPN residues  in  or on citrus  for
the following reasons:  1) the residue  data  submitted were
for pulp or peel instead of whole  fruit;  2) no  data reflected
aerial applications; 3) no tests reflected use  of an  emulsifiable
concentrate formulation; 4) geographic  representation was poor;
and 5) the representative commodities of  the Citrus Fruits Group
(lemons, grapefruit, oranges) were not  represented.  The following
data are required:

     0  Residue data from whole sweet oranges,  lemons,  and
        grapefruit harvested 30 days after the  last  of  several
        foliar applications with an  emuslifiable  concentrate
        formulation of EPN at 2.25 Ib ai/A.  The  data must
        reflect both aerial and ground  applications, and must
        include separate tests for use  of  ULV  equipment.
        Tests must also reflect ground  applications of  the
        25% wettable powder formulation at 0.5  Ib ai/100 gal
        (>2000 gal/A).  The studies  involving  oranges and
        grapefruit should take place in California and  Florida;
        those involving lemons should take place  in California
        »nd Arizona.  These states represent the  major  United
           ates production areas of the  representative citrus
           Dps.  If the maximum residue  values  determined for
           r  two of  the three crops differ by more than  a factor
           five, separate tolerances should be  proposed for
           :h of three crops, since a crop  group tolerance would
            be appropriate.  The registrant must  propose a
           .imum Ib  ai/A rate to complement the  0.5 Ib ai/100 gal
           e for ground applications of the 25% wattable powder
           mulation since it is unlikely  that  >2000  gal/A will
           applied.  The Agency recommends a maximum rate of
           Ib ai/A.

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                             -57-

     0  Residue data from the processed products  of  oranges,
        including dried pulp, oil, molasses,  and  juice,
        processed from oranges bearing measurable,  weathered
        EPN residues.  Exaggerated rates may  be reguired  to
        achieve such residue levels.  If EPN  is found  to
        concentrate  in any of these  products, appropriate
        food and/or  feed additive tolerances  must be proposed.

     There is no Canadian tolerance nor is there  a Codex  MRL
for residues of EPN  in or on citrus  fruit.  A Mexican  tolerance
of 3 ppm has been established for residues of EPN in or on
citrus fruit.

     Pome Fruits Group

     A crop group tolerance is not appropriate at this time
for the following reason:

     0  Data are reguired to support the established tolerances
        for residues of EPN in or on two representative crops,
        apples and pears.

          Apples

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations and the 25% wettable powder formulation of EPN
are registered for foliar applications at 0.125 to 0.375  Ib
ai/100 gal beginning at petal fall and continuing  at 10-  to
14-day intervals as  needed.  The 5 Ib/gal emulsifiable
concentrate formulation is registered for the same type of
application at 1 to  1.5 Ib ai/A.  A 21-day PHI is  in effect.
Emulsifiable concentrate formulations may be  applied using
aerial or ground eguipment.  ULV eguipment is also permitted
for emulsifiable concentrate formulations.  Applications  of
EPN may not be made  to Mclntosh or related varieties.  A
tolerance of 3 ppm has been established for residues of EPN
in or on apples.

     The submitted data are not adequate to support  the
established tolerance for residues of EPN in or on apples for
the following reasons:  1) maximum application rates were not
represented; 2) rates in gal/A were not provided;  and  3)  no
aerial application data were submitted.   The  following data
are required:

     0  Residue data from mature apples harvested  21 days
        after the last of several foliar ground applications,
        beginning at petal fall and continuing at  10-day
        intervals thereafter, of the 25% wettable  powder
        foHrtulation.  In separate tests,  residue  data  from
        mature apples harvested 21 days  after the  last of
        several foliar ground applications of an  emulsifiable
        concentrate  formulation at 0.375 Ib ai/100 gallons
        (800 gal/A).  These tests must also reflect  both

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                             -58-
        aerial and ground ULV application of an emulsifiable
        concentrate formulation at 3 Ib ai/A (800 gal/A rate
        at 0.375 Ib ai/100 gal adjusted to maintain Ib ai/A
        rate).  The tests should take place in Washington,
        New York, Michigan, Virginia, and California,  which
        collectively account for approximately 70 % of the
        United States apple production.  The registrant must
        also propose a maximum Ib ai/A rate for applications
        for the 25% wettable powder and emulsifiable concentrate
        formulations to complement the registered 0.375 Ib
        ai/100 gal rate since it is unlikely that >800 gal/A
        will be applied.  The Agency recommends a maximum
        rate of 3 Ib ai/A.

     0  Residue, data from dried pomace and juice, processed
        from apples bearing measurable, weathered EPN residues.
        Exaggerated rates may be necessary to achieve such
        levels.  If concentration of residues occurs upon
        processing, appropriate food and/or feed additive
        tolerances must be proposed.

     There  is no Canadian tolerance nor is there a Codex MRL
for residues of EPN in or on apples.  A Mexican tolerance of
3 ppm has been established for residues of EPN in or on apples.

          Pears

     The 4  Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations and the 25% wettable powder formulation of EPN
are registered for foliar applications at 0.125 to 0.375 Ib
ai/100 gal  beginning at petal fall and continuing at 10- to
14-day intervals as needed.  The 5 Ib/gal emulsifiable
concentrate formulation is registered for the same type of
application at 1 to 1.5 Ib ai/A.  A 14-day PHI is in effect.
Emulsifiable concentrate formulations may be applied using
aerial or ground eguipment.  ULV eguipment is also permitted
for emulsifiable concentrate formulations.  A tolerance of 3
ppm has been  established for residues of EPN in or on pears.

     The submitted data are not adeguate to support the
established tolerance for residues of EPN in or on pears for
the following reasons:  1) maximum appliation rates were not
represented;  2) rates in gal/A were not provided; and 3) no
aerial application data were submitted for the emulsifiable
concentrate formulations.  The following additional data are
required:

      0  Residue data from mature pears harvested 14 days
        after the last of several foliar ground applications,
        beginning at petal fall and continuing at 10-day
        intervals thereafter, of the 25% wettable powder
        formulation.  In separate tests, residue data from
        mature pears harvested 14 days after the last of

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                             -59-

        several foliar  ground  applications  of  an  emuls if iable
        concentrate  formulation  at  0.375  Ib ai/100  gallons  (500
        gal/A).  These  tests must also  reflect  both aerial  and
        ground ULV application of an emulsifiable concentrate
        formulation  at  2 Ib ai/A (500 gal/A rate  at 0.375 Ib
        ai/100 gal adjusted to maintain Ib  ai/A rate).   The
        tests should be conducted in California and Washington/
        which collectively produce  approximately  73% of  the
        domestic pears.  The registrant must also propose a
        maximum Ib ai/A rate for applications  fo  the 25%
        wettable powder and emulsifiable concentrate formula-
        tions to complement the  registered  0.375  Ib ai/100
        gal  rate since  it  is unlikely that  >500 gal/A will  be
        applied.  The Agency recommends a maximum rate of 2
        Ib ai/A.

     There is no Canadian  tolerance nor is  there  a Codex MRL
for residues of EPN in or on pears.   A Mexican tolerance of
3 ppm has been established for the  residues  of EPN  in or on
pears.

          Quinces

     There are no registered uses of EPN on quinces.  A
tolerance of 3 ppm has been established for residues of EPN
in or on quinces.   Since EPN has no registered use  on quinces,
the Agency will revoke the currently established tolerance  for
residues of EPN in or on this crop unless the registrant proposes
a use and submits  appropriate  residue data in support of the
established tolerance.

     There is no Canadian or Mexican tolerance nor  is there
a Codex MRL for residues of EPN in or on quinces.

     Stone Fruits Group

     A crop group tolerance is not appropriate at this time
for the followirv  reason:

     0  Data are required to support the established tolerances
        for residues  of EPN in  or on fruit of the  representative
        crops,  cherries, peaches, and plums.

          Apricots

     The 25% wettable powder formulation is registered for
foliar applications at 0.125 to 0.625 Ib ai/100 gal or 0.25
Ib ai/100 gal plus 1.5% light medium oil.   The 4 Ib/gal and
5 Ib/gal emul.s if iable concentrate formulations are registered
for foliar applications at 1 to 1.5  Ib ai/A.  Foliar applications
may begin at petal  fall and continue at 10- to 14-day intervals
as needed.  A delayed dormant application may be made with  the
4 Ib/gal and 5  Ib/gal emulsifiable concentrate formulations at

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                             -60-

5 Ib ai/A (plus 1.5% oil) at bud swell.  TWo or  three bark
applications, made in summer when borer moths appear, may be
made at 0.313 to 0.75 Ib gal/100 gal with  the 25% wettable
powder or the 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations, or at 0.75 to 1.5 Ib ai/A using the 5  Ib/gal
emulsifiable concentrate formulation.  A 21-day  PHI  is in
effect.  Both aerialand ground-applied foliar applications  of
emulsifiable concentrate formulations may be made.   ULV
applications are also permitted.  A tolerance of 3 ppm has
been established for residues of EPN in or on apricots.

     No residue data were submitted in support of the established
tolerance for residues of EPN in or on apricots.  Data requested
for peaches will be translated to assess the established tolerance
for residues of EPN in or on apricots.

     There  is no Canadian or Mexican tolerance nor  is there a
Codex MRL for residues of EPN in or on apricots.

          Cherries

     The 25% wettable powder formulation is registered for
foliar applications at 0.125 to 0.625 Ib ai/100  gal  or 0.25
Ib  ai/100 gal plus  1.5% light medium oil.  The 4 Ib/gal  and
5 Ib/gal emulsifiable concentrate formulations are  registered
for foliar  applications at 0.125 to 0.375  Ib ai/100  gal.  The
5 Ib/gal emulsifiable concentrate formulation is also registered
for foliar  applications at 1 to 1.5 Ib ai/A.  Foliar applications
may begin at petal fall and continue at 10- to 14-day intervals
as  needed.  A single delayed dormant application may be made with
the 4  Ib/gal and 5  Ib/gal emulsifiable concentrate  formulations
at  5 Ib  ai/A (plus  1.5% oil) at bud swell.  Two  or  three bark
applications, made in early to late summer when  borers appear,
may be made  at  0.313 to 0.75 Ib gal/100 gal with the 25% wettable
powder or the 4 Ib/gal  and 5 Ib/gal emulsifiable concentrate
formulations, or  at 0.75 to 1.5 Ib ai/A using the 5  Ib/gal
emulsifiable concentrate formulation.  A 21-day  PHI  is in
effect.  Both aerial- and ground-applied foliar  applications
of  emulsifiable concentrate formulations may be  made.  ULV
applications are  also permitted.  A tolerance of 3 ppm has  been
established  for residues of EPN in or on cherries.

     The submitted  data  are not adequate to support  the
established tolerance for EPN residues in or on  cherries for
following reasons:  1) the data do not represent multiple
foliar applications at the maximum-registered use rates;
2)  aerial application data were not submitted;  3) geographic
representation  was not adequate; 4) no residue data  from
sour cherries were  submitted;  5) rates were not  given  in
Ib  ai/A; and 6) no  tests  reflected the use of 1.5% oil.
The following data are required:

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                             -61-

     0  Residue data from mature sweet and sour  cherries,
        harvested 21 days following the  last  treatment
        included in the following regimen:  1) one delayed
        dormant application using an emulsifiable  concentrate
        formulation at 5 Ib ai/A plus 1.5% oil;  2) foliar
        applications, beginning at petal fall and continuing
        at 10-day intervals until 21 days prior  to harvest,
        using (in separate tests):

          a)  the 25% wettable powder formulation  at  0.625  Ib
              ai/100 gal (ground application);

          b)  the 25% wettable powder formulation at  0.25 Ib
              ai/100 gal plus 1.5% light medium  oil (ground
              application); and

          c)  ULV applications (ground and aerial, in separate
              tests) of an emulsifiable concentrate formulation
              at 3.75 Ib ai/A (maximum expected  gal/A rate  of
              1000 at 0.375 Ib ai/100 gal adjusted to maintain
              Ib ai/A rate); and

        3)  two late summer bark applications of the  5  Ib/gal
        emulsifiable concentrate formulation at  1.5 Ib  ai/A.
        In the case of ground-applied high-volume foliar
        applications, 1000 gallons of spray mixture should  be
        applied per acre.  The tests should be conducted in
        Washington and Michigan, which account for approximately
        63% of the United States sweet cherry production and
        84% of the United States sour cherry production.  The
        registrant must also propose a maximum Ib ai/A rate
        to complement the Ib ai/100 gal rates for foliar
        applications since it is unlikely that >1000  gal/A
        will be applied.  The Agency recommends  maximum rates
        of 3.75 Ib ai/A for the emulsifiable concentrate
        formulations and 6.25 Ib ai/A for the 25% wettable
        powder formulation, unless 1.5% oil is added, in
        which case 2.5 Ib ai/A of the 25% wettable powder
        would be the maximum rate.

     There is no Canadian or Mexican tolerance nor is there a
Codex MRL for residues of EPN in or on cherries.

          Nectarines

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations are registered for foliar applications at 0.125 to
0.375 Ib ai/100 gal beginning at petal fail and  continuing to
10- to 14-day intervals as needed.  The foliar applications of
5 Ib/gal emulsifiable concentrate formulations may also be made
at 1 to 1.5 Ib ai/A.  The 4 Ib/gal and 5 Ib/gal  emulsifiable
concentrate formulations are also registered for one  delayed
dormant application at 5 Ib ai/A (mixed with 1.5% oil) at bud

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                             -62-

swell.  The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations are also registered for 2 to 3 bark applications
at 0.375 to 0.75 Ib ai/100 gal in early to late summer when
borer moths appear.  The 5 Ib/gal emulsifiable concentrate
formulation is also registered for bark applications at 0.75 to
1.5 Ib ai/A.  A 21-day PHI is in effect.   Both ground and
aerial, foliar applications are permitted.  ULV applications
are also permitted.  A tolerance of 3 ppm has been established
for residues of EPN in or on nectarines.

     No data have  been submitted in support of the established
tolerance for residues of EPN in or on nectarines.  Data requested
for peaches will be translated to assess the established tolerance
for residues of EPN in or on nectarines.

     There  is no Canadian or Mexican tolerance nor is there a
Codex MRL for residues of EPN in or on nectarines.

          Peaches

     The 25% wettable powder formulation is registered for
foliar applications at 0.125 to 0.625 Ib ai/100 gal plus
1.5% light medium  oil.  The 4 Ib/gal and 5 Ib/gal emulsifiable
concentrate formulations are registered for foliar applications
at 0.125 to 0.375  Ib ai/100 gal.  The 5 Ib/gal emulsifiable
concentrate formulation is also registered for foliar applications
at 1 to 1.5 Ib  ai/A or for ULV ground or aerial applications
at 0.42 to  0.625 Ib ai/A (3 to 10 gal/A).  Foliar applications
may begin at petal fall and continue at 10- to 14-day intervals
as needed.  A delayed dormant application may be made with  the
4 Ib/gal and 5  Ib/gal emulsifiable concentrate formulations at
5 Ib ai/A  (plus 1.5% oil) at bud swell.  Two or three bark
applications, made in summer when borer moths appear, may be
made at 0.313 to 0.75 Ib ai/100 gal with the 25% wettable
powder formulation or the 4 Ib/gal and 5 Ib/gal emulsifiable
concentrate formulations, or at 0.75 to 1.5 Ib ai/A using the
5 Ib/gal emulsifiable concentrate formulation.  a 21-day PHI
is in effect.  Foliar treatments with the emulsifiable concentrate
formulations may be applied by both aerial and ground equipment.
ULV applications are also permitted for the emulsifiable
concentrate formulations.  A tolerance of 3 ppm has been
established for residues of EPN in or on peaches.

     The submitted data are not adequate to support the
established tolerance for the residues of EPN in or on peaches
for the following  reasons:  1) the data do not reflect residues
in samples harvested at the 21-day PHI following multiple
applications at maximum permissible rates; 2) rates were not
given  in Ib ai/A;  3) geographic representation was poor; 4)
aerial application data were not submitted; and 5) no data
relect use  of the  25% wettable powder formulation at 0.25 Ib
ai/100 gal plus 1.5% oil.  The following data are required  to
support the established tolerance:

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                              -63-

      0  Residue data from  nature peaches harvested  21  days
        following the  last treatment  in the  following  regimen:

           1) one delayed dormant application using  an
             emulsifiable  concentrate  formulation  at 5 Ib
             ai/A plus  1.5% oil;

           2) foliar applications, beginning  at  petal fall
             and continuing at 10-day  intervals until  21
             days prior to  harvest using (in separate  tests):

               a) the 25%  wettable powder formulation  at
                  0.625 Ib ai/100 gal  (ground application);

               b) the 25%  wettable powder formulation  at
                  0.25 Ib  ai/100 gal plus 1.5%  light medium
                  oil  (ground application); and

               c) ULV applications (ground and  aerial,  in
                  separate tests) of an emulsifiable
                  concentrate formulation at 2  Ib ai/A
                  (maximum expected gal/A rate  of 500
                  adjusted to maintain  Ib ai/A rate);

           3) two late-summer bark applications  at 1.5  Ib
             ai/A using the 5 Ib/gal emulsifiable concentrate
             formulation at 1.5 Ib ai/A.  In the case  of ground-
             applied high-volume foliar applications,  500 gallons
             of spray mixture should be applied per acre.  The
             tests should be conducted in California and South
             Carolina,  which produce approximately 74% of
             peaches in the United States.   The  data required
             for peaches will also be used for assessment of
             the tolerance for residues of EPN  in or on
             nectarines and apricots.   The registrant must
             also propose  a maximum Ib ai/A rate to complement
             the Ib ai/100 gal rate for foliar applications
             since it is unlikely that >500 gal/A will be
             applied.   The Agency recommends  a  maximum rate
             of 2 Ib ai/A for the emulsifiable  concentrate
             formulations and 3.1 Ib ai/A for the 25% wettable
             powder  formulation,  unless 1-5%  oil is added in
             which case 1.25 Ib ai/A-of the 25%  wettable powder
             formulation would be the  maximum rate.

     There is no Canadian tolerance or nor is there a Codex MRL
for residues of EPN  in  or on peaches.   A Mexican tolerance for
residues of EPN in or on peaches has been established  at 3 ppm.

          Plums (fresh  prunes)

     The 25% wettable powder formulation is registered for
foliar applications  at 0.125 to 0.625  Ib ai/100 gal plus 1.5%
light medium oil.   The 4 Ib/gal and 5  Ib/gal  emulsifiable

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                             -64-

concentrate formulations are registered for foliar applications
at 0.125 to 0.375 Ib  ai/100 gal.  The 5 Ib/gal emulsifiable
concentrate formulation is also registered for foliar
applications at 1 to  1.5 Ib ai/A.  Foliar applications may
be in »t petal fall and continue at 10- to 14-day intervals as
needed.  A delayed single delayed dormant application may be
made with the 4 Ib/gal  and 5 Ib/gal emulsifiable concentrate
formulations at 5 Ib  ai/A (plus 1.5% oil) at bud swell.  Two  or
three bark applications, made in summer when borer moths appear/
may be made at 0.313  to 0.75 Ib ai/100 gal with the 25% wettable
powder formulation or the 4 Ib/gal and 5 Ib/gal emulsifiable
concentrate formulations, or at 0.75 to 1.5 Ib ai/A using the
5 Ib/gal emulsifiable concentrate formulation.  A 21-day PHI  is
in effect.  Foliar treatments with the emulsifiable concentrate
formulations may be applied by both aerial and ground equipment.
ULV applications are  also permitted for the emulsifiable
concentrate formulations.

     The submitted data are not adequate to support the
established tolerance  for residues of EPN in or on plums
(fresh prunes) for the following reasons:  1) the data do
not reflect multiple  foliar applications at maximum-
registered use rates;  2) rates were not given in Ib ai/A;
   no data reflect aerial or ground application of an
                                 , beginning at petal fall
             and continuing at 10-day intervals until 21
             days  prior  to harvest  using  (in  separate tests)

               a)  the 25% wettable  powder formulation at
                   0.625  Ib ai/100 gal (ground application);

               b)  the 25% wettable  powder formulation at
                   0.25 Ib ai/100 gal plus 1.5% light medium
                   oil (ground application); and

               c)  ULV applications  (ground and aerial,  in
                   separate tests) of an emulsifiable
                   concentrate formulation at  2 Ib  ai/A
                   (maximum expected gal/A rate of  500
                   adjusted to maintain Ib ai/A rate).

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                             -65-

          3) two late-summer bark applications at  1.5  Ib
             ai/A using the 5  Ib/gal  emulsifiable  concentrate
             formulation  at 1.5  Ib  ai/A.   In  the case  of ground-
             applied high-volume foliar applications,  500 gallons
             of  spray mixture  should  be applied per  acre.   The
             tests should be conducted in Oregon and Michigan,
             which account for approximately  69% of  the  United
             States plum  production The registrant must  also
             propose a maximum Ib ai/A rate to complement the
             Ib  ai/100 gal rate  for foliar applications  since
             it  is unlikely that >500 gal/A will be applied.
             The Agency recommends  a maximum  rate  of 2 Ib ai/A
             for the emulsifiable concentrate formulations  and
             3.1 Ib ai/A  for the 25% wettable powder formulation,
             unless 1.5%  oil is added in which case 1.25  Ib
             ai/A of the  25% wettable powder  formulation would
             be the maximum rate.

     0  Residue  data from dried prunes, processed from plums
        bearing  measurable, weathered EPN residues.  Exaggerated
        rates may be required  to achieve such residue  levels.
        If residues are found  to concentrate in the dried  fruit,
        an appropriate food additive  tolerance must be proposed.

     There is no Canadian or Mexican tolerance nor is there  a
Codex MRL for residues of EPN  in or on plums  (fresh prunes).

     Small Fruits Group

     A crop group tolerance is not  appropriate at this time
for the following reasons:

     0  Residue  data and  a use proposal are needed for four
        representative crops:   blueberries, cranberries,
        strawberries,  and blackberries (or another Rubus
        species).

     0  Data are required to support the established
        tolerance for  residues of EPN in or on grapes, a
        representative crop.

          Blackberries, Boysenberries, Dewberries,  Loganberries,
          Raspberries, Strawberries, and Youngberries

     There are currently  no registered uses of EPN on black-
berries, boysenberries, dewberries, loganberries, raspberries,
strawberries, and youngberries.  However,  tolerances of  3 ppm
have been established  for residues of EPN in or on  blackberries,
boysenberries,  dewberries, loganberries, raspberries, strawberries,
youngberries.  Since there are no registered uses of EPN for these
crops the Agency will revoke the established tolerances  unless  the
registrant proposes uses  for these crops and submits appropriate
residue data in  support of the established tolerances.

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                             -66-

     There are no Canadian or Mexican tolerances nor are there
Codex MRLs for residues of EPN in or on blackberries, boysen-
berries, dewberries, loganberries, raspberries, strawberries,
and youngberries.

          Grapes

     The 25% wettable powder formulation is registered for an
unspecified number of foliar applications to grapes at 0.125
to 0.25 lb ai/100 gal, and at 0.25 Ib ai/A.  The 4 Ib/gal and
5 Ib/gal emulsifiable concentrate formulations are also
registered for foliar applications at 0.125 to 0.25 lb ai/100
gal.  A 21-day PHI is in effect.  Both aerial and ground
applications of  the  emulsifiable concentrate formulation are
permitted.  Emulsifiable concentrate formulations may also be
applied with ULV equipment.  A tolerance of 3 ppm has been
established for residues of EPN in or on grapes.

     The submitted data  are not adequate to support the
established tolerance for residues of EPN in or on grapes
for the following reasons:  1) no data were submitted for
the emulsifiable concentrate formulations; 2) no data were
submitted for aerial application of  the emulsifiable concentrate
formualtions; 3) samples were not collected at the 21-day PHI;
and 4) geographic representation was poor.  The following data
are required:

     0  Residue  data from mature grapes, harvested 21 days
        after the last of several foliar applications made,
        in separate  tests, aerially  (including ULV applications)
        and with ground  equipment (including ULV and high-volume
        applications) using an emulsifiable concentrate formula-
        tion at  0.25 lb  ai/100 gal (250 gal/A) for high-volume
        applications and at 0.63 lb  ai/A for ULV applications.
        High-volume  foliar application tests (ground-applied)
        with the 25% wettable powder formulation must also be
        made at  0.25 lb  ai/100 gal (250 gal/A).  The ULV rate
        was calculated from the lb ai/100 gal  rate at a maximum
        expected gal/A of 250 to maintain the  correct rate of
        active ingredient per acre.  The applications should be
        made at  10-day intervals beginning at  bloom.  The
        registrant must  propose a maximum lb ai/A rate for
        high-volume  applications since the maximum expected
        gal/A rate  is 250.  The Agency recommends that a maximum
        rate of  0.63 lb  ai/A be proposed.

     0  Residue data from raisins, raisin waste, juice, wet
        pomace and dried pomace processed from grapes bearing
        measurable,  weathered EPN residues.  Exaggerated rates
        may be necessary to achieve  such residue levels.  If
        residues concentrate in any  of these processed products,
        appropriate  food and/or feed additive  tolerances must be
        proposed.

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                              -67-

     There is no Canadian tolerance nor  is  there  a Codex MRL
for  the  residues of EPN  in  or on  grapes.  A Mexican tolerance
of 3 ppm has been established for the residues  of EPN in or  on
grapes.

     Tree Nuts Group

     A crop group tolerance  is not appropriate  at this time  for
the  following reason:

     0   Data must be  submitted to support the established
         tolerances for residues of EPN in or on the
         representative crops:  almonds, pecans,  and  English
         walnuts.

          Almonds

     The 4 Ib/gal and 5  Ib/gal  emulsifiable  concentrate
formulations are registered  for an unspecified  number  of
foliar applications at 0.125  to 0.25 Ib  ai/100  gal using
aerial or ground equipment.  Use of ULV  applications
equipment is also permitted for the emulsifiable  concentrate
formulations.  The 25% wettable powder formulation is  also
registered for an unspecified  number of  foliar  applications
at 0.125 to 0 188 Ib  ai/100 gal (800 gal/A maximum),  using
ground equipment.  A 21-day PHI is in effect.  A tolerance
of 0.5 ppm has been established for residues of EPN in or
on almonds.

     No  residue data  have been submitted in  support of the
established tolerance for residues of EPN in or  on almonds.
Likewise, no data or  tolerance proposal  have been submitted
for residues of EPN in or on almond hulls.   The  following
data are required:

     0  Residue data  from mature almond  nutmeats and
        corresponding hulls, harvested 21 days after the
        last of several foliar ground applications of  an
        emulsifiable  concentrate formulation at, 0.25 Ib
        ai/100 gal (800 gal/A) using high-volume ground
        equipment and 2 Ib ai/A using ULV ground equipment,
        in separate  tests.  The data should  also reflect
        ULV aerial applications of the emulsifiable concentrate
        at 2 Ib ai/A.  The Ib  ai/A rate  for ULV applications
        was calculated from the maximum expected gal/A rate
        (800) at 0.25 Ib ai/100 gal to maintain the correct
        rate of  active ingredient  per  acre.   The tests should
        take place in California,  where  the majority of almonds
        are  produced  in the United States.   In addition, the
        registrant must propose a maximum Ib ai/A rate for
        foliar  applications to complement the maximum registered

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                             -68-

        Ib ai/100 gal rate (0.25) since it is unlikely that
        >800 gal/A will be applied.  The Agency recommends that
        a maximum rate of 2 Ib ai/A be proposed.

     There is no Canadian tolernce nor is there a Codex MRL for
residues of EPN in or on almonds.  A Mexican tolerance of 0.5 ppm
has been established for residues of EPN in or on nuts.

          Pecans

     The 25% wettable powder formulation and the 2 Ib/gal and
5 Ib/gal emulsifiable concentrate  formulations  are registered
for multiple foliar treatments as needed at 0.125 to 0.5 Ib
ai/100 gal.  The 4 Ib/gal and 5  Ib/gal emulsifiable concentrate
formulations are also registered for use at 1 to 3.5 Ib ai/A.
Emulsifiable concentrate formulations may be applied using
aerial or ground equipment.  Use of ULV equipment is also
permitted for applying emulsifiable concentrate formulations.
A 21-day PHI is in effect.  A tolerance of 0.5  ppm has been
established for residues of EPN in or on pecans.

     No  residue data have been submitted in support of the
established tolerance for residues of EPN in or on pecans.
The following data are required:

     0  Residue data from pecans harvested 21 days after  the
         last of several foliar applications with the 25%
        wettable powder  formulation and, in separate tests,
        an emulsifiable concentrate formulation, at 0.5 Ib
         ai/100 gal (1000 gal/A).   The data should also
        reflect, in separate tests, both ground and aerial ULV
         applications of  an emulsifiable concentrate formulation
         at 5 Ib ai/A.  The Ib ai/A rate for ULV applications
        was calculated from the maximum expected gal/A rate
         (1000) at 0.5 Ib ai/100  gal to maintain the correct
        rate of active ingredient  per acre.  The tests should
         take place in Georgia and  New Mexico, which together
         produce approximately 70%  of the United States pecan
         crop.  The registrant must also propose a maximum  Ib
         ai/A rate for foliar applications  to  complement  the
         maximum registered Ib ai/100 gal rate (0.5) since
         it  is unlikely that >1000  gal/A will  be applied.
         The Agency recommends that a maximum rate of 5 Ib
         ai/A be proposed.

     There  is no Canadian  tolerance nor  is there a Codex MRL
for residues of EPN in or on pecans.  A Mexican tolerance of
0.5 ppm  has been extablished for residues  of EPN in or on nuts.

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                             -69-

          Walnuts

     The 4 Ib/gal  emulsifiable  concentrate  formulation is
registered for multiple foliar  applications at 3 to  3.5  Ib
ai/A.  The 25% wettable powder  formulation  and the 4 Ib/gal
and 5 Ib/gal  emulsifiable  concentrate  formulations are also
registered for multiple foliar  applications at 0.125 to  0.25
Ib ai/100 gal.  Emulsifiable concentrate  formulations may be
applied using aerial or ground  equipment.  Applications  of
emulsifiable  concentrate formulations  is  also permitted  with
ULV equipment.  A  21-day PHI is in effect.  A tolerance  of
0.5 ppm has been established for residues of EPN in  or on
walnuts.

     No residue data have  been  submitted  in support  of  the
established tolerance for residues of  EPN in or on walnuts.
The following data are required:

     0  Residue data from  mature walnuts, harvested  21 days
        after the  last of  several applications of the 4  Ib/gal
        emulsifiable concentrate formulation at 3.5  Ib ai/A,
        beginning  at petal fall and continuing at 10-day
        intervals  using, in separate tests,  aerial and  ground
        equipment, including tests using ULV equipment.  Data
        reflecting the 25% wettable powder formulation are not
        required since the maximum-expected Ib ai/A  rate, based
        on 1000 gal/A, for this formulation is much  lower than
        3.5 Ib ai/A.  The  tests should take place in California,
        where the  majority of walnuts are grown.   The registrant
        must  also  propose  a maximum Ib ai/A rate for high-volume
        applications to complement the maximum Ib ai/100 gal
        rate.

     There is no Canadian  tolerance nor is there a Codex MRL for
residues of EPN in or on walnuts.  A Mexican tolerance of 0.5 ppm
has been established for residues of EPN in or on nuts.

     Cereal Grains Group

     A crop group  tolerance is  not appropriate at this time
for the following reason:

     0  Data are required for three additional representative
        commodities:  rice, sorghum and wheat.

          Corn

     The 4 Ib/gal  and 5 Ib/gal emulsifiable concentrate
formulations, the 25% wettable powder formulation, and the
2% and 4% granular formulations are registered for multiple
foliar applications on field and sweet corn  and corn grown
for seed at 0.47 to 0.5 Ib ai/A.  The 4 Ib/gal emulsifiable
concentrate formulation may be similarly applied to  field

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                             -70-

corn only at 0.75 lb ai/A.  A 14-day PHI is in effect for all
corn crops.  Emulsifiable concentrate formulations may be
applied both aerially and from the ground.  ULV applications
of emulsifiable concentrate formulations are also permitted.
A tolerance of 3 ppm has been established for residues of EPN
in or on corn.

     The submitted data support  the  established tolerance for
residues of EPN in or on corn; however, the Agency recommends
that the registrant or petitioner propose two separate tolerances
for residues of EPN in or on  1) field corn grain and 2) sweet
corn (kernels plus cob with husks removed) at the currently
established level of 3 ppm.  Data are required, however, to
determine  if residues of EPN concentrate  in field corn processed
products.  The following data are required:

     0  Residue data from corn processed products, including
        milled products, crude oil,  and refined oil, processed
        from corn grain bearing  measurable, weathered EPN residues.
        Exaggerated rates may be required to achieve such residue
        levels.  If residues are found to concentrate, appropriate
        food and/or feed additive tolerances must be proposed.

     There is no Canadian tolerance  nor is there a Codex MRL
for  residues of EPN in or on corn.   A Mexican tolerance of
3 ppm has been established for residues of EPN in or on corn.

     Forage, Fodder and Straw of Cereal Grains Group

     A crop group tolerance is not appropriate at this time
for  the following reasons:

     0  Additional data are required for  residues in or on
        corn forage, fodder and  silage.  Tolerances must be
        proposed for residues in or  on  these commodities.

     0  Data are required for two additional representative
        crops:  wheat and another cereal  grain.

          Corn Forage, Silage and Fodder

     The 4 Ib/gal and 5 Ib/gal emulsifiable concentrate
formulations, the 25% wettable powder formulation, and the 2%
and  4% granular formulations are registered for multiple  foliar
applications on field and sweet  corn and corn grown for seed at
0.47 to 0.5 lb ai/A.  The 4 Ib/gal emulsifiable concentrate
formulation may be similarly applied to field corn only at 0.75
lb ai/A.  A 14-day PHI is  in effect  for all corn  crops.
Emulsifiable concentrate formulations may be applied both
aerially and from the ground.  ULV applications of emulsifiable
concentrate formulations are also permitted.  There are no
tolerances for residues of EPN in or on corn forage, silage  or
fodder.

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                              -71-

     Since  EPN is registered  for use on  field  and  sweet  corn,
 tolerances  for residues  in  or on  the  following raw agricultural
 commodities must be proposed:   forage, silage/  and fodder.
 The  submitted data  are not  adequate to determine appropriate
 tolerances  for EPN residues in  or on corn  forage,  fodder and
 silage.  Therefore, the  following data are required:

     0  Residue data from sweet corn forage and field corn
        forage, fodder and  silage harvested after  the last
        of several foliar applications of  an emulsifiable
        concentrate formulation and in,  separate tests,  a
        granular formulation  and a wettable powder  formualtion
        at  0.75 Ib  ai/A.  The tests should include  aerial and
        ground ULV applications of an emulsifiable concentrate
        formulation.  Forage  must be collected  at  intervals
        following the last  application.  A pregrazing interval
        must be proposed.   Fodder and silage must  be harvested
        14 days after the last  treatment.  Test  should take
        place in Iowa, Indiana, Florida,  Minnesota, California,
        New York, and Tennessee, which collectively represent
        all of the major areas  of the United States where field
        and sweet corn foliage  would be used for forage,  fodder
        or  silage.

     There  are no Canadian  or Mexican tolerances nor is  there
 a Codex MRL for residues of EPN in or on  corn forage, silage,
 or fodder.

     Miscellaneous Commodities

          Cottonseed

     The 2 Ib/gal and 5 Ib/gal  emulsifiable concentrate
 formulations are registered for aerial or around multiple
 foliar applications at 0.313  to 1 Ib ai/A.  The  5 Ib/gal
 emulsifiable concentrate formulation may  also be used at  a
 lower rate of 0.188 Ib ai/A.  Use of ULV equipment is
 permitted.  A 3-day PHI is in effect.   Treated  forage or
 gin may not be fed to livestock.  A tolerance of 0.5 ppm
has been established for residues of EPN  in or on cottonseed.

     The submitted data are adequate to support  the established
 tolerance for residues of EPN in or  on the raw agricultural
 commodity, cottonseed.  The data are also  adequate to show
that concentration of  residues does  not occur upon processing
 cottonseed into meal,  but does occur,  at up to  approximately
40 times,  upon processing into oil.   The  registrant must
propose a food additive tolerance for residues of EPN in
cottonseed oil.   The Agency recommends that a tolerance  of
 20 ppm be proposed.  In addition,  the following  data are
required to determine  if EPN residues  concentrate in two
 other processed products, hulls and soapstock:

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                             -72-

     0  Residue data from cottonseed hulls and soapstock,
        processed from cottonseed bearing measurable,
        weathered EPN residues.  Exaggerated rates may be
        necessary to achieve such initial residue levels.
        If residues are found to concentrate in either product,
        appropriate feed additive tolerances must be proposed.

     There is no Canadian tolerance nor is there a Codex MRL
for residues of EPN in or on cottonseed.  A Mexican  tolerance
of 0.5 ppm has been established for residues of EPN in or on
cottonseed.

          Olives

     The 25% wettable powder formulation  is registered for an
unspecified number of ground-applied foliar applications at
<4 Ib ai/A (0.313 to 0.625 Ib ai/100 gal) or at 0.25 lb/100
gal when mixed with 1.5% light medium oil.  The 4 Ib/gal and
5 Ib/gal emulsifiable concentrate formulations are registered
for ground or  aerial foliar applications  at 4 to 12  Ib ai/A.
ULV treatments are permitted with the emulsifiable concentrate
formulations.  No PHI is in effect, but applications may not
be made after July 15.  A tolerance of 3 ppm has been established
for residues of EPN in or on olives.

     No data were submitted in support of the established
tolerance for  residues of EPN in or on olives.  Therefore, the
following data are reguired:

     0  Residue data from mature olives harvested from trees
        which received several foliar applications of the
        4 Ib/gal or 5 Ib/gal emulsifiable concentrate formulation
        at 12  Ib ai/A and, in separate tests, of the 25% wettable
        powder formulation at 0.25 Ib ai/100 gal plus 1.5%
        light medium oil (800 gal of spray/A).  The  last
        application should be made on July 15.  Residue data
        reflecting both aerial and ground applications, including
        the use of ULV equipment, with an emulsifiable concentrate
        formulation must be submitted.  Only ground  application
        data are reguired for the 25% wettable powder formulation.
        Tests must be conducted in California.
     o
        Residue data from olive oil, produced from olives bearing
        measurable, weathered residues of EPN.  Exaggerated rates
        may be necessary to achieve such initial residue levels.
        If concentration of residues does take place, an appropriate
        food additive tolerance must be proposed.

     There is no Canadian or Mexican tolerance nor is there a
Codex MRL for residues of EPN in or on olives.

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                             -73-

          Pineapples

     There are currently no  registered uses  of EPN on  pineapples.
However, a tolerance of 3 ppm has been established for residues
of EPN in or on pineapples.  Since  there  is  no registered  use
of EPN for this crop the Agency will revoke  the established
tolerance unless the registrant proposes  a use and submits
appropriate residue data in support of the established tolerance,

     There is no Canadian  tolerance nor is there a Codex MRL
for residues of EPN in or on pineapples.  A  Mexican tolerance
of 3 ppm has been established for residues of EPN in or on
pineapples.

     Magnitude of the Residue in Meat, Milk/ Poultry and Eggs
     Tolerances have not been proposed or established  for
residues of EPN in the fat, meat and meat by-products  of
cattle, goats, hogs, horses, sheep or poultry, or for the
residues of EPN in milk or eggs.

     There are no direct animal treatments for EPN on  cattle,
goats, hogs, horses, sheep or poultry.  Tolerances have been
established for residues of EPN in or on  the following raw
agricultural commodities on which registered uses exist and
which may either be fed directly (unprocessed) or processed
into commodities which may be fed to livestock:   sugar beets
(tops, dehydrated pulp, mollasses), beans (seeds, vines,  hay,
cannery residue), soybeans (seed, meal, hulls, ensiled hay,
straw, forage, soapstock), citrus (pulp, molasses), apples
(dehydrated pomace), almonds (hulls), corn (grain, forage,
silage, fodder, cannery waste), cotton (seed, seed meal,
hulls, soapstock), tomatoes  (pomace) and grapes (pomace and
raisin waste).  Since additional data are required to  support
tolerances for residues of EPN in or on many of  these raw
agricultural commodities and data are needed to determine
whether concentration of residues occurs on processing, the
Agency is unable to estimate the maximum expected intake of
EPN residues by cattle, poultry or swine at this  time.
(Refer to the section of this document entitled "Magnitude
of the Residues in Plants" for details of data requirements.)
Also, the nature of the residue in animals has not been
adequately described.  Therefore, the Agency will not assess
the adequacy of the available data at the present time.
However, it has been determined that 14C-residues of  [14C]EPN
transfer to the tissues of poultry and that EPN per se
constitutes a major percentage of the residues in fat.   (Refer
to the section of this document entitled "Nature  of the Residue
in Animals" for details. )  Upon receipt of the requested animal
metabolism data, and data pertaining to residues  in major feed
items, the adequacy of the available data will be assessed and
specific data requirements regarding residues in  animal products
will be determined.

     There are no Canadian or Mexican tolerances nor are there
Codex MRLs for residues of EPN in or on animal products.

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                             -74-

2.  Pesticide Monitoring Data

     No information has been received to date from the United
States Department of Agriculture pertaining to monitoring data,
although the Agency has requested such information.  Data are
available, however, from the Food and Drug Administration for
samples of several crops analyzed between fiscal years 1978
and 1984.  These data are summarized below.
                                                Residue Range (ppm)
Ap pi e s
Rice hulls
Rice bran
Wheat
Okra
Peppers (1980)
Mustard greens
Lettuce
Spices
Peppers (1983)
Peppers (1984)
1
1
1
1
1
1
1
1
1
4
2
0.06
0.27
0.14
trace
0.10
0.38
trace
0.02
0.02
0.03 - 0.86
0.09 - 0.59
Of the crops represented, only apples and lettuce have EPN
registrations and tolerances for residues of EPN.  The values
reported are well below the established tolerances.  The measurable
EPN residues in the other corps, which do not have EPN registrations
or tolerances for residues of EPN, may represent illegal use of
EPN in the United States or may represent use of EPN on crops
imported from other countries.  Seven samples of peppers, in
three different years, contained an average of 0.35 ppm EPN.
However, the fifteen crop samples reported are apparently the
only samples having measurable EPN residues out  of 50,000 samples
tested in fiscal years 1978 thru 1984.  The Agency will request
that FDA conduct further monitoring on these crops to determine
how widespread the problem may be.  Subsequently, the registrants
may be asked to submit data proposing tolerances for these  crops.

3.  Toxicology Data and Acceptable Daily Intake  (ADI)

     The Acceptable Daily Intake (ADI) or Provisional Acceptable
Daily Intake (PADI), if there are inadequate toxicology data to
establish an ADI, and the Maximum Permissible Intake (MPI)  are
ways of expressing the amount of substance that the Agency  believes,
on the basis of the results of data from animal  studies and the
application of "safety" or "uncertainty" factors, may safely be
ingested by humans without risk of adverse health effects.  The
ADI and PADI are expressed in terms of milligrams  (mq) of the
substance per kilogram (kg) of body weight per day (mg/kg/day).

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                              -75-

The MPIf a related figure based on whole body  exposure,  is
obtained by assuming  a  human  body weight of  60 kg,  and is
expressed  in  terms of mg  of substance  per  day  (mg/day).

     Section  I I.E. of this document  discussed  the regulatory
history of EPN relative to the Agency's earlier assessment of
neurotoxicity studies in  which it concluded  that the subchronic
(90-day hen)  delayed  neurotoxicity study was inadeguate  and
that the Agency would rely on a human  cholinesterase inhibition
study  to assess toxicological risks  to consumers and workers.
However, with the subseguent submission of the  new, acceptable
delayed neurotoxicity studies (90-day  and  recovery), the Agency
now believes  that these two studies are more appropriate  to use
for risk assessments.

     These assessments  are provided  in subsections B.9.  and 10.,
above.  In summary, the Agency concludes that the NOEL of  0.01
mg/kg/day  from irreversible nerve damage in  the spinal cord
is appropriate to use at this time to  establish a PADI.   Because
the NOEL is from a subchronic study, a 1000-fold safety  factor
(or uncertainty factor) is being used, which results in  a  PADI
value  of 0.00001 mg/kg/day.  The MPI value is  therefore  0.0006
mg/day-  The  theoretical maximum residue contribution  (TMRC),
which  is the  maximum  amount of a pesticide that would be  in  the
human  diet, is 0.9859 mg/kg/day.  The TMRC is based on the
assumptions of an average body weight  of 60  kg, a 1.5 kg  daily
diet,  and  certain food factors for the commodities with  EPN
tolerances (Table 4 on page 31).  Based on the  PADI value of
0.00001 mg/kg/day, the TMRC is 164,000 percent  of the PADI.
For reasons discussed in subsection B, the Agency believes this
percentage is likely  to be exaggerated due to unrealistic
residue (tolerance) values and the assumption of 100% of crop
acreage treated.  Table 5 on page 32 presents a more likely
assessment for five crops based on actual  residue data and
percent of crop treated

     At this  time, the Agency concludes that the present TMRC,
which  is a measure of the upper limit of possible dietary
exposure,  is  far greater than what is  reasonably likely  to  be
found  in practice, but there are several data gaps.   When the
additional chronic feeding studies necessary to establish an
ADI are submitted and the extensive  residue chemistry and
toxicology data gaps  are filled, the Agency will again evaluate
the percentage of the ADI utilized.   In the meantime the Agency
will not approve any  significant^ new uses for EPN,  including
group  tolerances.  In the Special Review of EPN, the Agency will
consider cancellation of some or all uses of EPN and will
consider revoking tolerances.
6 "Significant new use is defined in 44 FR 27934, May 11, 1979.
In the case of a new food or feed use, the Agency will generally
consider as significant an increase in the Theoretical Maximum
Residue Contribution (TMRC) of greater than 1%.

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                             -76-

4.  Tolerance Reassessment Summary and Current Tolerances

     It should be noted that data gaps exist for the storage
stability and metabolism of EPN in plants and animals.
Because the requested data and perhaps the continued adequacy
of all established tolerances are dependent upon the results
of the studies in the "Residue Data" section above, it  is
imperative that the metabolism data be collected prior to
the requested residue data.  Furthermore, the conclusions
stated below are subject to change on receipt of the
requested metabolism data and storage stability data.

     Sufficient data are available to ascertain the adequacy
of the established tolerances for residues of EPN  in or on
the following raw agricultural commodities (RACs):  beans
(dried), cottonseed, tomatoes, and corn.  In order to be
consistent with the commodity definitions listed in
40 CFR 180.34 (f), the Agency requires (1) that the
tolerance for residues in or on corn be  changed to two
tolerances, each at 3 ppm, for residues  in or on field  corn
grain and sweet corn (kernels plus cob with husks  removed) and
(2) that the tolerance for residues  in or on beans be changed to
three tolerances for residues in or on dried beans, at 3 ppm,
and lima and snap beans for which additional data  are required.

     Additional data are required to support the established
tolerances for residues in or on  almonds, apples,  apricots,
beans (snap and lima only), cherries, citrus, grapes, lettuce,
nectarines, olives, peaches, pears,  pecans, plums,  soybeans,
sugar beets (without tops), and walnuts.
     Also, residue  data  and EPN usage proposals are  required
to support tolerances  for residues in or on beets and beet
greens, blackberries, boysenberries, dewberries, loganberries,
pineapples, quinces, raspberries, rutabagas, spinach,
strawberries, turnips  and turnip greens, and youngberries;
alternatively, the  Agency will move to revoke these  tolerances.
The Agency will  also move to  revoke the  tolerance for residues
in or on  rutabaga tops since  rutabaga tops are not presently
considered a  raw agricultural  commodity  (RAC) of rutabagas
and no registered use of EPN on rutabagas exists.

     In addition to the  conclusions given above regarding
established tolerances, the following requirements and
recommendations are made pertaining to residues in RACs  and
processed products:

     1) data  are required to  determine whether food  and/or
feed additive tolerances are needed for residues in  the
following processed products:  dehydrated sugar beet pulp,
sugar beet molasses, refined sugar beet sugar, soybean hulls,
soybean soapstock,  bean  cannery residue, wet and dried tomato

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                             -77-

poroace, tomato puree, tomato catsup, tomato juice, dried
citrus pulp, citrus oil, citrus juice, citrus molasses, dried
prunes, raisins, raisin waste, grape juice, wet and dried
grape pomace, apple juice, wet and dried apple pomace,
cottonseed hulls, cottonseed soapstock, crude and refined
corn oil and corn milling products, and olive oil.

     2) data and tolerance proposals for residues of EPN in
or on corn forage, silage and fodder, almond hulls, and
soybean forage and straw are required.

     3) data and tolerance proposals for residues of EPN in
or on bean vines and hay and sugar beet tops and pregrazing
interval proposals for bean vines and sugar beet tops must be
submitted; alternatively, feeding and grazing restrictions
may be proposed.

     4) food additive tolerances must be proposed for residues
of EPN in cottonseed oil and soybean oil;  the data indicate
that a tolerance of 20 ppm will be adequate for residues in
cottonseed oil; a food additive tolerance 6 times the acceptable
tolerance for soybeans will be appropriate for residues in
soybean oil.

     5) crop group tolerances for EPN are not appropriate at
this time because extensive additional residue are needed.
Also, since most of the required toxicological studies are
missing and data are required in order to  estimate dietary
exposure, no new tolerances either group or otherwise,  or
new uses, will be established.

     The Agency's calculation of the ADI for EPN is discussed
in detail in Section III. D. 3. "Toxicology Data and Acceptable
Daily Intake (ADI)" above.

     Tolerances issued

     The present United States tolerances (40 CFR 180.119)
and Mexican tolerances are listed on the following page.   There
are no Canadian tolerances or Codex MRL's  established for EPN.

     The regulatory results of  the Agency's review are  set  out
in Section IV.A., Regulatory Positions and Rationales.

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                             -78-

                             EPN

                Summary of Present Tolerances
Commodity

Apples
Apricots
Beans
Beets
Beet greens
Blackberries
Boysenberries
Cherries
Citrus fruits
Corn
Dewberries
Grapes
Lettuce
Loganberries
Nectarines
Olives
Peaches
Pears
Pineapples
Plums (fresh prunes)
Quinces
Raspberries
Rutabagas
Rutabagas tops
Spinach
Strawberries
Sugarbeets (but not sugar
            beet tops)
Toma toes
Turnips
Turnip greens
Youngberries
Almo nds
Cottonseed
Pecans
Walnuts
Soybeans
Nuts
                           Tolerance  (ppm)
United States
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
0.5
0.5
0.5
0.5
0.05
	
Mexico
3.0
	
3.0
	
	
	
_._ _
	
3.0
3.0
	
3.0
3.0
_ —
— _
___
3.0
3.0
3.0
___
— 	
» __
— — _
M -__
3.0
3.0
	
3.0
— — —
_ __
— _ _
_ -.—
0.5
— «_
— .— —•
0.05
0.5

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                             -79-

            IV.  REGULATORY POSITION AND RATIONALE

           A.  Regulatory Positions and Rationales

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

1.   EPN is being placed in Special Review.

     Rationale:  The Agency is initiating a Special Review  for
     all registered uses of EPN based on the results of the
     delayed neurotoxicity studies, and risks to workers
     involved with EPN application and working in fields
     treated with EPN and the risks to the public from con-
     sumption of food ccmmodities containing EPN residues.
     The delayed neurotoxicity effects and the risks from
     continued use of EPN meet or exceed the criteria for
     unreasonable adverse effects (40 CFR 154.7(a)(2)).  The
     Agency is also concerned about the toxicity of EPN to
     aquatic and avian species and is requesting actual and
     simulated field studies to assess the potential toxic
     effects of EPN to these organisms.

          The Agency has reviewed the comments received in
     response to the Preliminary Notification to Registrants
     issued pursuant to 40 CFR 154.21.  The comments do not
     change the Agency's position regarding the  need for
     Special Review of EPN.

          Therefore, the Agency is placing EPN in the Special
     Review Process.  The comments received by the Agency will
     be addressed in detail in the Federal Register
     Notice which the Agency plans to issue.

2.   The Agency will continue to restrict all uses of  liquid
     and dry (granular and wettable powder) formulations
     of EPN greater than 4%.

     Rationale;  The restricted use classification was originally
     imposed on EPN liquid and dry formulations  greater than 4%
     in January 1981 because of its acute dermal toxicity, acute
     inhalation toxicity and residue effects on  avian  species.
     Acute toxicity data available to the Agency show  that EPN
     continues to meet or exceed these criteria  for  restricted
     use.  Therefore,  the Agency will continue to classify EPN
     liquid and dry formulations greater than 4% for restricted
     use.

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                             -80-

3.   In order to remain in compliance with FIFRA, registrants
     must amend their labels to incorporate a label statement
     concerning the histopathological changes in the spinal
     cord and delayed neurotoxicity to be used in conjunction
     with the restricted use statement.

     Rationale;  The Agency believes that a statement of the
     reason for a product's restricted use classification should
     be included on the labels of restricted use products.   This
     statement affords the product user with important information
     about the potential product hazard(s) that are associated
     with the use of the product and are the foundation for
     the restricted use classification.

4.   The Agency does not believe that a groundwater advisory
     statement on EPN labeling is necessary at this time.

     Rationale; Data currently available to the Agency are
     insufficient to either assess the environmental fate of EPN
     or to characterize its leaching potential for contamination
     of ground water.  EPN was not included in the Special Ground-
     water Data Call-in Notice the Agency issued on March 31,
     1984.  Data allowing assessment of the leaching potential
     and environmental fate of EPN are required.

5.   Pending  receipt of acute delayed  neurotoxicity
     data on  which to base the risk assessment to determine
     the most effective reentry interval for EPN, the Agency
     has determined that the following reentry intervals are
     necessary in order for these products to remain in
     compliance with FIFRA;  7 days for corn and cotton;
     35 days  for citrus; and 2 days for all other crops.
     The reentry intervals were chosen based on MOSs shown
     in Table 7.

     Rationale;  Preliminary evaluation of recently submitted
     toxicity and dissipation data indicate that the 24-hour
     reentry  interval established in 1974 for EPN under
     40 CFR 170.3 (b)(2) does not provide adequate protection
     for fieldworkers.  Therefore, the Agency is establishing
     these new and longer reentry intervals.  However, upon
     receipt  and review of the required acute delayed neuro-
     toxicity data the Agency may need to revise these reentry
     intervals.

6.   The Agency has determined that, in order to meet applicable
     FIFRA standards, protective clothing must be worn by mixer/
     loaders  and applicators and that all EPN end-use product
     labeling must contain work safety rules, precautionary
     statements, and protective clothing statements.  (Refer to
     Section  IV. D. for the required protective clothing labeling)

     Rationale;  EPN is an organophosphate chemical that can
     induce cholinesterase inhibition upon repeated significant
     exposure and has been shown to produce delayed neurotoxicity

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                             -Bl-

     and histopathological changes  in  the  spinal  cord  in labora-
     tory animals.  To protect workers against the acute  toxicity
     and potential nerve damage of EPN, protective clothing  (a
     protective suit of one or two pieces that covers  all  parts
     of the body except the head, hands/ and feet; chemical
     resistant gloves and chemical resistant boots, shoes, or
     shoe coverings) is necessary to lessen worker exposure
     during the mixing, loading and application of EPN.  The
     required work safety rules and precautionary labeling
     statements provide specific guidance for persons handling
     EPN products, describe the required protective clothing
     and equipment for use, as well as procedures for  minimizing
     exposure to EPN contaminated materials.

7.   Endangered species labeling may be required at a  later date
     for certain use patterns of EPN.

     Rationale;  EPN is toxic to certain endangered/threatened
     species of mammals, birds, aquatic organisms, crustaceans,
     reptiles and insects.   The Agency, in an attempt  to limit
     use of EPN in areas where its use may be detrimental  to
     endangered/threatened species,  will require that  endangered
     species information be included on labeling of end-use
     products which contain certain terrestrial food crop  and
     terrestrial nonfood use patterns.  The required  labeling
     will be based on Biological Opinions by the Office of
     Endangered Species (OES) of the Fish and Wildlife Service,
     U. S.   Department of Interior.   The Agency has developed
     labeling to protect endangered species from exposure  to
     EPN and will impose these labeling requirements through
     a Pesticide Registration (PR) Notice which addresses not
     only EPN,  but other pesticides with similar uses, determined
     to cause jeopardy to endangered species.

8.   The Agency is requiring an aquatic residue monitoring
     study or a mesocosm study.

     Rationale;  Ecological effects data currently available
     to the Agency are insufficient  for estimating EPN's
     environmental contamination potential.  The above
     studies are necessary  in order  for the Agency to estimate
     environmental contamination and to complete the assessment
     of the persistence of EPN relative to its  chronic toxicity
     or bioaccumulation potential.

9.   The Agency does  not believe that a rotational crop
     restriction is necessary.

     Rationale;  The Agency lacks appropriate rotational crop
     data  at the present tine to determine whether planting
     food or feed crops in EPN-treated soils would result  in
     illegal residues in these  crops.  If required data
     demonstrate that follow-up crops take up EPN residues
     from soil, rotational  crop restrictions or tolerances
     in those crops may be neccesary.

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                             -82-

10.  The Agency cannot conduct a full tolerance  reassessment
     for EPN at this time.

     Rationale:  Data gaps exist for plant and animal metabolism,
     storage stability, magnitude of the residues in several raw
     agricultural commodities and processed food and feed items,
     in addition to toxicology data gaps in the  area of chronic
     f eed ing/oncogen icity.   Upon receipt of the data required in
     Table A, the Agency's  conclusions with regard to the adequacy
     of established tolerances are subject to change.  Since the
     data required for individual commodities are dependent on
     the metabolism data, the metabolism data will be obtained
     and reviewed prior to  any required residue  data.

11.  No significant7 new uses, including group tolerances, will
     be granted while EPN is  in the Special Review process and
     until the Agency has received data sufficient to evaluate
     the dietary exposure to EPN.

     Rationale;  The current  tolerance assessment, based on the
     subchronic delayed neurotoxic effect, residues at tolerance
     levels and 100% crop treated, shows a Theoretical Maximum
     Residue Contribution (TMRC) which occupies 164,000% of
     the Provisional Acceptable Daily Intake (PADI).  While
     calculation of the five crops for which there are residue
     data, based on percent crop treated, shows roughly
     acceptable intake levels, many other tolerances and data
     gaps remain.  The residue chemistry and toxicology data
     bases for EPN are not  sufficient to assess the existing
     tolerances or to establish crop group tolerances.  Plant
     and animal metabolism data and residue data on various
     commodities are required.  The pertinent toxicology data
     requirments include:  chronic feeding/ oncogenicity, and
     reproduction.  (Refer  to Appendix I, Table A, for a listing
     of residue chemistry and toxicology data required).  Until
     these data are submitted and reviewed, the Agency cannot
     perform a full tolerance reassessment for EPN.  The Agency
     believes that allowing significant dietary exposure to
     pesticides for which a full tolerance reassessment  is
     impossible would not adequately protect the public.

12.  The Agency has determined that the tolerances for beets and
     beet greens, blackberries, boysenberries, dewberries, logan-
     berries, pineapples, quinces, raspberries, rutabagas, spinach,
     strawberries, turnips  and turnip greens, and youngberries
     should be revoked because there are no registered uses of
     EPN for these raw agricultural commodities.  Alternatively,
7 "Significant new use" is defined in 44 FR 27934, May 11, 1979.
In the case of a new food or feed use, the Agency will generally
consider as significant an increase in the Theoretical Maximum
Residue Contribution (TMRC) of greater than 1%.

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                             -83-

     the residue data and usage proposals  are  required  for each
     of the above crops.  This data roust be submitted by
     September 26, 1988 to avoid revocation action  by the  Agency

     Rationale; There are currently no registered uses  for
     EPN on these crops.  The Agency can not evaluate the
     adequacy of the tolerance in the absence of directions
     for use.

13.  The Agency will move to revoke the tolerance for residues
     of EPN in or on rutabaga tops.
     Rationale:  Rutabaga tops are not presently considered  a
     agricultural commodity of rutabagas.  In addition, there i
     no registered use of EPN on rutabagas at the present time.

14.  The Agency is requiring processing data for the following
     raw agricultural commodities:   sugar beets, soybeans,
     tomatoes, citrus, prunes, grapes, apples, cottonseed,
     corn, and olives.

     Rationale;  The Agency has no data to determine whether
     residues of EPN concentrate when these commodities are
     processed into food or feed items.

15.  The Agency believes that the addition of the telephone
     number of the National Pesticide Telecommunications
     Network to the labels of all end-use EPN products is
     necessary in order for such products to meet applicable
     FIFRA standards.

     Rationale;  The telephone number  is included in order
     to provide a source of first aid information in the
     event of an exposure accident.

16.  While data gaps are being filled, currently registered
     manufacturing use products (MPs) and end use products
     (EPs) containing EPN as the sole active ingredient may
     be sold, distributed, formulated and used,  subject to
     the terras and conditions specified in this Standard.
     Registrants must provide or agree to develop additional
     data, as specified in the Data Appendices,  in order to
     maintain existing registrations.

     Rationale;  Under FIFRA, the Agency may choose not to
     cancel or withhold registration if data are
      missing or are inadequate (see FIFRA sec.  3(c)(2)(B)
      and 3(c) (7) ).
raw
is

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                             -84-

                B.   CRITERIA FOR REGISTRATION

    To be registered or reregistered under this Standard,
products must contain EPN as the sole active ingredient, bear
required labeling,  and conform to the product composition,
acute toxicity limits, and use pattern requirements listed
in this document.

    The applicant for registration or reregistration of
manufacturing use products subject to this standard must comply
with all terms and conditions described, including submission of
an up-to-date Confidential Statement of Formula, submission of
revised labeling, commitment to fill data gaps on the schedule
as specified by the Agency and, when applicable, offer to pay
compensation as required by sections 3(c)(l)(D) and 3(c)(2)(D)
of the Federal Insecticide, Fungicide, and Rodenticide Act
(FIRFA), as amended, 7 U.S.C. 136 (c)(2)(D).  Registrants of
end-use products who qualify for the Formulator's Exemption**
must submit five (5) copies of draft labeling incorporating
the unique label statements identified  in Section D of the
document.  Registrants of end-use products who do not qualify
for the Formulator's Exemption must comply with the terms and
conditions set forth above for manufacturing-use registrants.

               C.  ACCEPTABLE RANGES AND LIMITS

     1.  Product Composition Standard

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

     2.  Acute Toxicity Limits

    The Agency will consider registration of technical grade
and manufacturing-use products containing EPN provided that
the product labeling bears appropriate precautionary statements
for the acute toxicity category in which each product is
placed.
O
0  As of the date of issue of this registration standard,
   there are no registrations for Technical EPN
   products or manufacturing-use products in the United
   States.   Therefore,  registrants of end-use products
   containing EPN do not qualify for the Formulator's
   Exemption at this time.

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                             -85-
     3.  Use Patterns
     To be registered under  this Standard, manufacturing-use
products  ay be labeled for  formulation into end-use products
only for  the commodities listed below.

                    Terrestrial Food Crop
                     (Agricultural Crops)
           Almond
           Apple
           Apricot
           Beans
           Black-eyed Peas
           Cherry
           Citrus Citron
           Citrus Fruits
           Corn, Field
           Corn (seed crop)
           Corn, Sweet
           Cotton
           Cowpeas
           Grapefruit
           Grapes
           Green Beans
           Kumquat
           Lemon
           Lima Beans
           Lime
Navy Beans
Nectarine
Olive
Orange
Peach
Pear
Pecan
Plum
Prune
Red Kidney Beans
Snap Beans
Sour Cherries
Soybeans
Sugar Beets
Sweet Cherries
Tangelo
Tangerine
Toma to
Walnut
                    Terrestrial Non-Food Crop

           Earthworm Farms
    The "EPA Index to Pesticide Chemicals" lists all
uses of EPN, as well as approved maximum application
frequencies.
                    registered
                    rates and
                    D.  REQUIRED LABELING

     All manufacturing-use products and end-use products
must bear appropriate labeling as specified in 40 CFR 162.10,
PR Notices 83-2 and 83-3, and as indicated in this Registration
Standard, as appropriate to the use.  Appendix II contains
information on labeling requirements.

     No end-use or manufacturing-use product containing EPN
may be released frr shipment by a registrant or producer of
that product after April 30, 1988, unless the product bears
an EPA-approved amended label which complies with this
Registration Standard.

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                             -86-

     No end-use or manufacturing-use product containing EPN
may be distributed, sold/ offered for sale, held for sale,
shipped, delivered for shipment, or received and (having
been so received) delivered or offered to be delivered by
any person after April 30, 1989, unless the product bears
an EPA-approved amended label which complies with this
Registration Standard.

     In addition to the above, the following information must
appear on the labeling:

1. All Products

     Pesticide Disposal Statement.  The following pesticide
     disposal statement must appear on all labels:

    "Pesticide wastes  are  acutely hazardous.  Improper disposal
     of excess pesticide, spray mixture, or rinsate is a violation
     of Federal Law.   If these wastes cannot be disposed of by use
     according to  label instructions, contact your State Pesticide
     or Environmental  Control Agency, or the Hazardous Waste
     representative at the nearest EPA Regional Office for
     guidance."

2.  Manufacturing-use  Products - All manufacturing-use products
must bear the  following statements:

     Ingredients Statement.  The  ingredient statement  for
     Manufacturing-use Products must list the active ingredient
     as:

        O-ethyl 0-p-nitrophenyl phenylphosphonothioate

     Use Pattern Statements.  All manufacturing-use products
     must state  that  they  are  intended for  formulation into
     end-use products  for acceptable use patterns.  Labelina
     must specify  sites, which  are  listed  in Use Patterns,
     Section C.3.  However, no use may be included on the
     label where the  registrant  fails  to agree  to  comply with
     the data reguirements in Table A  for that use pattern.

     Precautionary Statements.  The following statement must
     appear in the Environmental Hazards section of the label
     for all Manufacturing-use  Products:

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

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                             -87-

3.  End-use Products - Labels for end-use  products must  bear
the statementsin quotes below.

     Restricted Use Statement.  All  liquid formulations  and
     any formulation greater than 4% EPN are classified  as
     restricted use pesticides and must bear the  following
     statement in a prominent position on  the  front  panel  of
     the label:

                  "RESTRICTED-USE PESTICIDE

     Due to acute toxicity and demonstration of delayed
     neurotoxicity and irreversible  nerve  damage  in the
     spinal cord in laboratory animals.

     For retail sale to and use only by Certified  Applicators
     or persons under their direct supervision and only  for
     those uses covered by the Certified Applicator's  certifi-
     cation.  Direct supervision for this  product  is defined
     as the Certified Applicator being physically  present
     during mixing, loading/ equiplment repair/ and  equipment
     cleaning.  Applicators must ensure that all persons
     involved in these activities under direct supervision
     are informed of the precautionary statements."

     Precautionary Statements.  The following statements must
     appear in the Hazards to Humans section of the  label
     for all End-use Products:

                     "WORK SAFETY RULES

     REPEATED EXPOSURES TO CHOLINESTERASE INHIBITORS SUCH
     AS ARE CONTAINED IN THIS PRODUCT MAY, WITHOUT WARNING/
     CAUSE PROLONGED SUSCEPTIBILITY TO VERY SMALL DOSES OF
     ANY CHOLINESTERASE INHIBITOR.

     Persons working with this product should have frequent
     blood tests of their cholinesterase levels.   If the
     cholinesterase level falls below a critical point/ no
     further exposure should be allowed until  it has been
     determined by means of blood tests that the cholinesterase
     level has returned to normal.  Before using this  product
     consult the National Pesticide Telecommunication Network
     for recommendations regarding such blood tests/ poisoning
     management/  emergency treatment, and other information
     regarding the toxicity of EPN.   The toll free number  for
     the National Pesticide Telecommunication Network is
     1-800-858-7378.

     CAUSES DELAYED NEUROTOXICITY IN LABORATORY ANIMALS
     FOLLOWING A LARGE SINGLE DOSE OR SEVERAL/  SMALLER,
     DAILY DOSES.   Neurotoxicity may occur after recovery
     from acute effects.   No antidote for delayed neurotoxicity
     exists - symptomatic treatment only.

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                        -88-

If handled indoors provide mechanical exhaust ventilation.

Keep all unprotected persons, children, livestock, and
pets away from treated area.

DO NOT APPLY THIS PRODUCT WHEN WEATHER CONDITIONS FAVOR
DRIFT FROM TREATED AREAS.

Do not rub eyes or mouth with hands.  If  you feel sick
in any way, STOP work and get help right  away.  See
First Aid (Practical Treatment) section.

HANDLE THE CONCENTRATE AND LOAD THE  GRANULES ONLY WHEN
WEARING THE FOLLOWING PROTECTIVE  CLOTHING AND EQUIPMENT:

Wear a protective suit of one or  two pieces that covers
all parts of  the body except the  head, hands, and feet.

Wear chemical resistant gloves, chemical  resistant apron,
and chemical  resistant shoes, shoe  coverings, or  boots.

Wear goggles or a face shield.  Wear a pesticide respirator
approved by the National Institute  for Occupational  Safety
and Health under the provisions of  30 CFR part  II.

If handling the concentrate with  a  closed system, a  long
sleeved shirt and long legged pants may be substituted
for the protective  suit  and the respirator  requirement
is waived.

WEAR THE FOLLOWING  PROTECTIVE CLOTHING AND  EQUIPMENT
DURING APPLICATION, EQUIPMENT REPAIR, EQUIPMENT CLEANING,
DISPOSAL OF EXCESS  SPRAY SOLUTION,  AND DURING REENTRY
TO TREATED AREAS PRIOR TO THE EXPIRATION  OF THE REENTRY
INTERVAL:

Wear a protective suit of one or  two pieces  that  covers
all parts of the body except the  head, hands, and feet.
Wear chemical resistant gloves and  chemical  resistant
boots, shoes, or shoe coverings.

Application must be made only from  a tractor with a
completely enclosed cab or aerially  with  an enclosed
cockpit.  For these applications  a  long sleeved shirt
and long legged pants may be worn in place  of the above
protective clothing.  Chemical resistant  gloves must be
available in the cab or cockpit and  must  be  worn  while
exiting.  This clothing  is  inadequate to  protect  you
during equipment repair, cleaning or reentry.

IMPORTANT!  Before  removing gloves,  wash  them with  soap
and water.  Always wash hands, face, and  arms with soap
and water before smoking, eating, drinking, or  toileting.

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                         -89-

AFTER WORK, take  off  all  clothes  and shoes.   Shower
using soap  and water.   Wear only  clean clothes.   Do not
use contaminated  clothing.   Wash  protective  clothing
and protective equipment with soap and water after each
use.  Respirators must  be cleaned  and filters  replaced
according to  instructions included with the  respirators.
Personal clothing worn  during use  must be  laundered
separately  from household articles.   Clothing  and
protective  equipment  heavily contaminated  or drenched
with EPN must be  destroyed  in accordance with  state and local
regulations.  HEAVILY CONTAMINATED OR DRENCHED CLOTHING
CANNOT BE ADEQUATELY  DECONTAMINATED.

DURING AERIAL APPLICATION,  HUMAN  FLAGGERS  ARE  PROHIBITED
UNLESS IN A TOTALLY ENCLOSED VEHICLE."

Precautionary Statements.   The  following statements must
appear in the Environmental Hazards  section  of  the label
for all end-use emulsifiable  concentrate and wettable
powder formulations:

"This pesticide is toxic  to fish  and  wildlife.   Do not
apply directly to water or  wetlands  (swamps, bogs,
marshes and potholes).   Runoff  and drift from  treated
area may be hazardous to  aquatic organisms in  adjacent
aquatic sites.  Do not  contaminate water by  cleaning  of
equipment or disposal of  wastes.

This product  is highly  toxic  to bees  exposed to  direct
treatment or residues on  blooming  crops  and  weeds.
Do not apply  this product or allow  it to drift  to
bloomina crops or weeds if  bees are  visiting the
treatment area."

Re-entry Statements.  The following  statement must
appear in the re-entry section of  the  label  for  all
end-use products:

"Do not reenter fields  treated with EPN  to perform tasks
requiring contact with  EPN  treated surfaces  within:
7 days for  corn or cotton crops;  35  days for citrus;  or
48 hours for other crops  unless the protective clothing
specified in the  "Precautionary Statements -- Hazards  to
Humans" section is worn."

Directions for Use Statements.  The  following statement
must appear in the Directions for  Use  section  of  the
label for all end-use emulsifiable  concentrate  and
wettable powder formulations:

"Do not apply this product  when weather  conditions favor
drift from treated areas."

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                        -90-

Cotton.  The statement listed below must appear on
end-use emulsifiable concentrate and wettable  powder
products intended for use on cotton:

"Do not apply to blooming cotton if bees are visiting
the treatment area."

Field or Sweet Corn.  The statement listed  below must
appear on end-use emulsifiable concentrate  and wettable
powder products intended for use on field or sweet  corn:

"Do not apply to corn during the pollenshed"period  if
bees are visiting the treatment area."

Stone Fruits/ Pome Fruits and Citrus.  The  statement
listed below must appear on end-use emulsifiable
concentrate and wettable powder products intended for
use on stone fruits, pome fruits and citrus:

"Do not apply when trees or a substantial number of
weeds in the orchard/grove are  in blocm."

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                             -91-

            V.  PRODUCTS SUBJECT TO THIS STANDARD

     All products containing one or more of the pesticides
identified in Section 11.A. are subject to certain requirements
for data submission or changes in composition/ labeling or
packaging of the product.  The applicable requirements depend
on whether the product is a manufacturing or end use product
and whether the pesticide is the sole active ingredient or
one of multiple active ingredients.

    Products are subject to this Registration Standard as
follows:

A.  Manufacturing use products containing this pesticide as
the sole active ingredient are subject to:

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

     2.  The data requirements listed in Tables A and B9

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

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

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

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

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                             -92-

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

     The data requirements listed in Table A.

C.  End use products containing this pesticide as the
sole active ingredient are subject to:

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

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

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

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

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

     a.  If not eligible for the formulator's exemption,
     the data requirements listed in Tables A and C.

     b.  If eligible for the formulator's exemption, the
     data requirements listed in Table C.
10 If you purchase from another producer and use as the
source of your active ingredient only EPA-registered products,
you are eligible for the formulator's exemption for generic
data concerning that active ingredient (Table A) and product-
specific data for the registered manufacturing use product
you purchase (Table B).
     Two circumstances nullify this exemption:

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

     2)  if no producer subject to the generic data requirements
in Table A agrees to submit the required data, all end use
producers lose the exemption,  and become subject to those
data requirements.  This has occurred for EPN.

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                              -93-

       VI.  REQUIREMENT  FOR  SUBMISSION  OF  GENERIC  DATA

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

A.  What are generic  data?

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

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

B.  Who must submit generic  data?

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

     If you are granted  a generic data exemption,  you  rely on
the efforts of other persons to provide the Agency with  the
required data.  If  the registrants  who have  committed  to
generate and submit the required data fail to take appropriate
steps to meet  the  requirements  or are no longer in compliance
with this data requirements  notice, the Agency will consider
that both  they and  you are not  in compliance and will  normally
initiate proceedings to suspend the registrations  of both
your product(s) and their product(s)  unless  you commit to  submit
and submit the required data in the specified timeframe.   In
such cases, the Agency generally will not grant a  time  extension
for submitting the  data.
11 Registrations granted after  issuance of this Standard will
be conditioned upon submission  or citation of the data  listed
in this Registration Standard.

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                             -94-

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

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

C.  What generic data must be submitted?

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

D.  How to comply with PCI requirements.

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

     1.  You will submit the data yourself.

     2.  You have entered into an agreement with one or more
registrants to jointly develop (or share in the cost of
developing) the data, but will not be submitting the data
yourself.  If you use this method, you  must state who  will
submit the data on which you will rely.  You must also provide
EPA with documentary evidence that an agreement has  been
formed which allows you to rely upon the data to be  submitted.
Such evidence may be:  (1) your letter  offering to  join in
an agreement and the other registrant's acceptance  of  your
offer, (2) a written statement by the parties that an  agreement
exists, or (3) a written  statement by the person who will  be
submitting the data that you may rely upon its  submission.

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                              -95-

The Agency will also require  adequate  assurance  that  the
person whom you state will provide  the data is taking appropriate
steps to secure it.  The  agreement  to  produce  the  data need
not specify all of  the  terms  of  the final  arrangement between
the parties or a mechanism to resolve  the  terms.

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

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

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

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

     In order to qualify for this method,   you  must:

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

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

-------
                             -96-

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

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

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

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

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

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

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                             -97-

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

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

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

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

F.  Procedures for requesting a change in testing protocol.

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

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

G.  Procedures for requesting extensions of time.

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

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                             -98-

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

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

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

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

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

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

I.  Existing stocks provision upon suspension or cancellation.

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

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                              -99-

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

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

     2.   Demonstration that such  a provision would be consis-
     tent with the provisions  of  FIFRA.
   VII. REQUIREMENT FOR SUBMISSION  OF  PRODUCT-SPECIF1C DATA

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

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

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

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

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                             -100-

    VIII.  REQUIREMENT FOR SUBMISSION OF REVISED LABELING

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

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


               IX.  INSTRUCTIONS FOR SUBMISSION

A.  Manufacturing Use Products (MUPs) containing the subject
    pesticide as sole active ingredient.

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

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

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

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

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

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                             -101-

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

        a.  Application for Pesticide Registration  (EPA
    Form 8570-1).

        b.  Two copies of any required product-specific data
    (See Table B).

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

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

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

B.  Manufacturing Use Products containing the subject  pesticide
    in combination with other active ingredients.

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

        a.  FIFRA sec. 3(c)(2)(B) Summary Sheet, with  appropriate
    attachments11 (EPA Form 8580-1).

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

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

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

        a.  Application for Pesticide Registration  (EPA
    Form 8570-1).

        b.  Two copies of any required product-specific data
    (See Table B)'.

        c.  Three copies of draft labeling, including  the

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                             -102-

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

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

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

C.  End Use Products containing the subject pesticide as an
    active ingredient.

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

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

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

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

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

        a.  Application for Pesticide Registration (EPA
     Form 8570-1).

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

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

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

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                             -103-

D.  Intrastate Products containing the subject pesticide either
    as sole active ingredient or in combination with other
    active ingredients.

    These products are being called in for full Federal regis-
tration.  Producers of these products are being sent a letter
instructing them how to submit an application for registration.

E.  Addresses

     The required information must be submitted to the following
address:

     Dennis Edwards (PM 12)
     Registration Division (TS-767C)
     Office of Pesticide Programs
     Environmental Protection Agency
     401 M St. , SW
     Washington, D.C.   20460

     The address for submissions to the Office of Compliance
Mon i tor i ng is:

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

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I.  DATA APPENDICES

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                             -104-

                           TGUIDE-1

                       GUIDE TO TABLES

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

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

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

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

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

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

2.  Test Substance (Column 2).  This column lists the composition

of the test substance required to be used for the test, as
follows:

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

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

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

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

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

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                             -105-

                           TGUIDE-2

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

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

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

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

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

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

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

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

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                                    -106-

                                 TABLE A
GENERIC DATA REQUIREMENTS FDR Oethyl Op-nitrcphervl phenylphosphonothioate
[EPN]
Data Requirement Composition
§158.120 Product Chemistry
Product Identity
61-2 - Description of Beginning
Materials and Manufacturing
Process
61-3 - Discussion of Fomation of
Inpurities
Analysis and Certification of
Product Ingredients
62-1 - Preliminary Analysis
62-2 - Certification of Ingredient
Limits
62-3 - Analytical Methods to Verify
Certified Limits
Physical and Chemical
Characteristics
63-2 - Color
63-3 - Physical State
63-4 - Odor
63-5 - Melting Point
63-6 - Boiling Point
TGAI
TGAI
TGAI
IGAI
1GAI
IGAI
IGAI
TGM
IGAI
IGAI
Use
Patterns
All
All
All
All
All
All
All
All
All
All
Does EPA
Have Data?1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Bibliographic
Citation1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Mist Additional
Data be
Submitted?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No 3/
Yes
Timefrane
For Data
Submission 2
6 Months
6 Months
12 Months
12 Months
12 Months
6 Months
6 Months
6 Months
6 Months
6 Months

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                                                          -107-

                                                     TABLE  A
                      GENERIC DATA REQUIREMENTS FDR Oethyl  Op-nitrcphervl  pherylphosphonothioate     [EPN]
Data Requirement
               Use      Does EPA    Bibliographic  Must Additional
Composition  Patterns   Have Data?* Citation1      Data be
                                                   Submitted?
                                            Time Frame
                                               for
                                            Submission 2
§158.120 Product Chemistry (Continued)

Physical and Chemical Characteristics
(Continued)

  63-7  - Density, Bulk Density, or
          Specific Gravity
                                           TGAI
                All
N/A
N/A
Yes
6 Months
63-8
63-9
63-10
63-11
63-12
63-13
Other
64- 1
- Solubility
- Vapor Pressure
- Dissociation constant
- Octane]/ water partition
coef f icient
-pH
- Storage Stability
Requirements:
- Submittal of sanples
TGAI or PAI
PAI
PAI
PAI
TGAI
TGAI
TGAI, PAI
All
All
All
All
All
All
All
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
Yes
Yes
Reserved 4/
6 Months
6 Months
6 Months
6 Months
6 Months
15 Months
6 Months
TGAI = Technical Grade of the Active Ingredient;  EAI  = Pure Active  Ingredient; R = Required; CR = Conditionally Required

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

2.  Data itust be submitted within the indicated tins  frame. The  beginning date for these tine frames is March 26, 1987,
    the date of the Agency's most recent Data Call In Notice  calling in these  data.
      6 Month Due Date is	SEPTEMBER 26, 1987	;   12 Month Due Date is 	MARCH 26, 1988	.

3/  Not required because EPN is a liquid at room  temperature.

4/  T£  samples  aire needed the Agency will request than.

-------
                                                           -108-
               GENERIC DATA REQUIREMENTS FOR CHEMICAL:
                                                       TABLE A
                                                       O-ethyl-O-p-nitropheryl pherylphosphonothioate   ' [EPN]
Data Requirenents
                                         Composition
Dbes EPA Have Data
To Satisfy This
Requi rene nt?   (Yes,
No, or Partially)
Bibliographic
  Citation
Must Additional Data
Be Submitted Under
F1FRA § 3(c)(2)(B)?
Time Frames For Data
Submission^
                                             PAIRA

                                          PAIRA and Plant
                                          Metabolites
§158.125 Residue Chemistry

  171-4 - Nature of Residue  (Metabolism)

        - Plants

        - Livestock

  171-4 - Residue Analytical Method

        - Plant residues



        - Animal residues

        - Storage Stability  Data

  171-^4 - Magnitude of the Residue-
           Residue Studies for Each
           Food Use

        - Root and Tuber Vegetables Group

          Beets                              TEP

          Rutabagas                           TEP

          Sugar beets                         TEP
  Partial

  Partial
                                          TGAI and Metabolites  Yes



                                          TGAI and Metabolites  No

                                          TGAI and Metabolites  No
                                                               No

                                                               No

                                                               No
00109147
 Yes3  18 Months
00079794;00079794  Yes4  18 Months
00085429
                       00068437; 00068905  No
                       00079807;00100090
                       00100099; GSO147-0 01
                       00101107
                                          Reserve d^

                                          Yes6  15 Months
                                          Yes7

                                          Yes7

                                          Yes8  24 Months

-------
                                                           -109-
               GENERIC DATA REQUIREMENTS FOR CHEMICAL:
              TABLE A
              O-ethyl-O-p-nitropheryl  pherylphosphonothioate     [EPN]
Eat a Requirements
Composition
Does EPA Have Data
To Satisfy This
Requirement?   (Yes,
No, or Partially)
Bibliographic
  Citation
Mist Additional Data
Be Submitted Under
FIFRA § 3(c) (2) (B)?
Time Frartes For Data
Submission2
§158.125 Residue Chemistry  - Continued

          Turnips                            TEP               No

        - Leaves of Root and Tuber Vegetables Group

          Beet tops (greens)                 TEP               No

          Ritabaga  tops                       TEP               No

          Sugar beet tops                     TEP               No

          Turnip tops (greens)                TEP               No

        - Leafy Vegetables  (Except Brassica Vegetables) Group

          Lettuce                            TEP               No

          Spinach                            TEP               No

          Beans                              TEP               No

          Soybeans                            TEP               Partial

        - Foliage of the Legume Vegetables Group

          Beans vines and hay                 TEP               No

          Soybean forage and straw            TEP               No

        - Fruiting Vegetables (Except Cucurbits) Group

          Tomatoes                            TEP               Partial
                                                              Yes/



                                                              Yes7

                                                              Yes7

                                                              Yes9  24 Months

                                                              Yes7



                                                              Yes10 18 Months

                                                              Yes7

                                                              Yes11 18 Months

                                          00068905            Yes12 18 Months



                                                              Yes13 18 Months

                                                              Yes14 18 Months



                                          00068437;00100090   Yes15 24 Months

-------
                                                           -110-
                                                       TABIE A
               GENERIC DATA REQUIREMENTS EDR CHEMICAL:  Oe thy 1-O-p-ni trap hery 1 pherylphosphonothioate
                                                                 [RPN]
Data Requirement
Coonposition
Does EPA Have Data
To Satisfy This
Requi rene nt?  (Yes,
No or Partially)
Bibliographic
  Citation
Must Additional Data
Be Submitted Under
ETFRA § 3(c)(2)(B)?
Time Frames for Data
Submission 2
§158.125 Residue Chemistry - Continued

        - Citrus Fruits Group

          Citrus Fruits

        - Pome Fruits Group

          Apples

          Pears

          Quinces

        - Stone Fruits Group

          Apricots

          Cherries

          Nectarines

          Peaches


          Plums (fresh prunes)

        - Small Fruits Group

          Blackberries
    TEP




    TEP

    TEP

    TEP




    TEP

    TEP

    TEP

    TEP


    TEP




    TEP
    Partial



    Partial

    Partial

    No



    No

    Partial

    No

    Partial


    Partial



    No
000683 67; 000684 37    Yes16 24 Months
00100078; 00100099

00068437;00100078
00100099
00068367;00068437
00068367;00068437
00100078;00100099

00100078
   Yes17 24 Months

   Yes18 18 Months

   Yes7



   Yes19 18 Months

   Yes20 18 Months

   Yes21 18 Months

   Yes22 24 Months


   Yes23 24 Months



   Yes7

-------
                                                           -111-
                                                       TABLE A
                GENERIC DATA REQUIREMENTS FOR CHEMICAL:  O-etlyl-O-p-nitrcpheryl pherylphosphonothioate      [EPN]
Data Requirement
Composition
Does EPA Have Data
To Satisfy This
Requi rone nt?  (Yes,
No or Partially)
Bibliographic
  Citation
        - Cereal Grains Group

          Corn
    TEP
   Partial
        - Forage,  Fodder and Straw of Cereal Grains Group

          Corn forage,  silage  and  fodder     TEP
                       Partial
Must Additional Data
Be Submitted Under
FTFRA § 3(c)(2)(B)?
Time Frames for Data
Submission 2
§158.125 Residue Chemistry - Continued
Boysenberries
Dewberries
Grapes
Loganberries
Raspberries
Strawberries
Youngberries
- Tree Nuts Group
Almonds
Pecans
Walnuts

TEP
TEP
TEP
TEP
TEP
TEP
TEP

TEP
TEP
TEP

No
No
Partial
No
No
No
No

No
No
No

Yes7
Yes7
0006836 7;00100078 Yes24
Yes7
Yes7
Yes7
Yes7

Yes25
Yes26
Yes27



24 Months





18 Months
30 Months
18 Months
00068437;00068905   Yes28 36 Months
00100088
                       00068437; 00068905   Yes29  24 Months
                       00100088

-------
                                                           -112-
                                                       TABLE A
                GENERIC DATA REQUIREMENTS RDR CHEMICAL:  Oetbyl-O-p-nitrcpheivl pherylphosphonothioate
                                                                  [EPN]
Data Requirenent
Cornposition
Does EPA Have Data
To Satisfy This
Requi rene nt?  (Yes,
No or Partially)
Bibliographic
  Citation
Must Additional Data
Be Submitted Under
FIFRA § 3(c)(2)(3)?
Time Frames for Data
Submission 2
§158.125 Residue Chemistry - Continued

        - Miscellaneous Crops

          Cottonseed

          Olives

          Pineapples

        - Meat/Milk/Poultry/Eggs


 171-4 - Special Processing Studies:
    TEP

    TEP

    TEP

    TGAI or Plant
     Metabolites

    TEP
       - To Provide Residue Data for Cocked
            (Microwaveing and Boiling)  Sveet Corn

       - To Provide Residue Data on Fresh Unwashed Tomatoes

       - A Vfeshing Study to Provide Residue  Data on Lettuce
 171-13 - Submittal of Analytical
           Reference Standards
   BVIRA
   Partial

   No

   No
   No


   No

   No


   No
00068905;00089025   Yes30 36 Months

                    Yes31 24 Months

                    Yes7
                    Yes   24 Months


                    Yes   24 Months

                    Yes   24 Months


                    No

-------
                                                           -113-

                                                       TABLE  A
                 GENERIC DATA RBDUIREMENTS FOR CHEMICAL:   <>ethyl-O-p-nitrcpheryl pherylphosphonothioate      [EPN]

§158.125 Residue Chemistry - Continued

1.  Composition:  TGAI = Technical grade of the active  ingredient;  EftlRA = Pure active  ingredient, radiolabelled; TEP =
    Typical end-use product; EP = End-use product.

2.  Data must be submitted within the indicated time frame.   The beginning date for these  time  frames  is March  26, 1987,
    the date of the Agency's most recent Data Call  In Notice  calling  in  these data.
      6 Month Due Date is _ SEPTEMBER 26, 1987   ; 15 Month Due  Date is        JUNE 26,  1988 _ ;
     18 Month Due Date is _ SEPTEMBER 26, 1988  ; 24 Month Due  Date  is _ MARCH  26, 1989 _ ;
     30 Month Due Date is _ SEPTEMBER 26, 1989   ; 36 Month Due  Date is        MARCH  26, 1990       .
3.  Data nust be submitted reflecting the  distribution and  metabolism of benzene ring-labeled  [cjEPN in  (i) nature
    cottonseed harvested 3 days after several foliar applications  at 1  Ib  ai/A made 4-5 days apart;  (ii) field corn
    fodder and nature field corn grain harvested 14 days  after several  applications at 0.5 Ib  ai/A made 5 days apart;
    and (ii) nature pecans harvested 21 days  following the  last  of several foliar applications at 7-day intervals at 3.5
    Ib ai/A.  The rates stated here are based on maximum  use rates;  exaggerated rates may be necessary to obtain
    sufficient residues in the harvest portion for  char acteri ration.  Analyses should include  hydrolysis and reextraction
    of plant residues and aqueous extracts to determine conjugated 14C-residues of EPN.  If the metabolism results
    differ sicyiif icantly among the three crops, then additional  netabolism data must be submitted for a representative
    crop in each crcp group for which registered uses of  EPN exist.  If the  required data indicate additional residues of
    toxicological concern, the tolerance definition will  be  changed  accordingly.  The registrant should conduct the
    required netabolism studies and submit them to  the Agency for  review prior to conducting the required field studies.

4.  No tolerances exist for residues of EPN in animal products.  The submitted data pertaining to the netabolism
    of EPN in animals indicate that EPN residues will transfer to  tissues of poultry, but otherwise  are inadequate to
    show the nature of those residues in poultry or other animals.   Therefore, ne tabo Is im studies utilizing ruminants are
    required.  Animals must be dosed for three days with  ring-labeled [14C]EPN at a concentration in the total diet
    which will result in sufficient residue in the  tissues and milk  for characterization.  Animals nust be sacrificed
    within 24 hours of the final dose (milk must be collected twice  daily).  14C-Residues must be characterized and
    quantified in milk, nuscle, fat,  kidney,  and liver.   If  residues of toxicological concern are found to transfer to
    the tissues and/or milk of ruminants,  appropriate tolerances must be proposed.

    Metabolism studies utilizing poultry are  also required.   Animals nust be dosed for three days with ring-labeled
    [14C]EPN at a concentration in the total  diet which will result  in  sufficient residue in the tissues and eggs for
    characterization.  Animals must be sacrificed within  24  hours of the final dose (eggs must be collected twice
    daily).   14C-Residues nust be characterized and quantified in eggs, nuscle, fat,  kidney, and liver.  If residues

-------
                                                          -114-

                                                      TABLE A
                 GENERIC DATA REQUIREMENTS EDR CHEMICAL:  O-ethyl-O-p-nitrqpheryl phenylphosphonothioate      [EPN]

§158.125 Residue Chemistry - Continued

    of toxicological concern are found  to transfer to  the tissues  and/or eggs of poultry/ appropriate tolerances must
    be proposed.  Furthermore, if  the nature  of the residue in poultry differs significantly from that in ruminants,
    additional data depicting the nature of the residue  in swine will be required (i.e. in the absence of rat metabolism
    data).  If poultry and ruminant netabolian differ  from that in the rat, then additional swine data are required.

5.  If residues of toxicological concern are found to  transfer to  the tissues and/or milk of ruminants or to the tissues
    and/or eggs of poultry and appropriate tolerances  are proposed, then analytical nethods must be submitted with the
    tolerance proposal.

6.  No data have been submitted regarding the stability of EPN residues in or on plant samples in frozen storage.  There-
    fore data are required.   Storage conditions and harvest-to-analysis intervals must be submitted for the samples of
    corn grain, sweet corn,  tomatoes, cottonseed,  and  soybeans from which residue data were collected and used to support
    established tolerances for residues in or on corn, tomatoes, beans  (dried), and cottonseed.  Data reflecting the
    storage stability of EPN in plant samples at  the  intervals specified must be submitted.  If storage stability is
    poor, conclusions regarding the adequacy of tolerances for residues in or on these commodities may change.

    All residue data required in this standard must be accompanied by information pertaining to the conditions and
    intervals of sample storage as well as fortification and recovery data reflecting the stability of EPN at such
    intervals.

7.  The registrant must submit usage proposals and data  to support the  established tolerance.  Otherwise, the Agency
    will move to revoke this tolerance, as there are no registered uses for EPN on this commodity.  This data must
    be submitted by September 26,  1988  to avoid revocation by the Agency.

8.  Residue data from sugar  beet roots  taken 21 days following the last of several foliar applications with a registered
    EC formulation at 1 Ib ai/A, using  ground and  aerial equipment, including UIV equipment (separate tests) are
    required.  The tests should take place inCA,  ID,  MN, and ND which collectively account for approximately 67% of
    U.S. sugar beet production.

    Data reflecting residues of EPN in  dehydrated  pulp, molasses, and refined sugar processed from sugar beets bearing
    Measurable waathered residues are required.  If residues concentrate in any of these processed products, appropriate
    food/feed additive tolerances must  be proposed at the time these data are submitted to the Agency.

9.  Sugar beet tops are a raw agricultural commodity of sugar beets.  Therefore, residue data and a tolerance proposal
    must be submitted or feeding and grazing restrictions must be  proposed.  The following data must be submitted  if

-------
                                                           -115-

                                                       TABLE A
                  GENERIC DATA REQUIREMENTS FOR CHEMICAL:   O-eth/1-Op-nitrcphervl pherylphosphonothioate      [EPN]

 §158.125 Residue Chemistry - Continued

     a tolerance is proposed:  residue data from sugar beet tops harvested at  regular  intervals following the  last of
     several foliar applications with a registered  EC  formulation  at  1 Ib ai/A, using  ground and aerial equipment,
     including ULV equipment (separate tests).   The tests should take place in CA, ID, MN, and ND which collectively
     account for approximately 67% of U.S.  sugar beet  production.

10.  The only product which contains  this use at this  tine  is an intrastate product for use in California only.  Vhen this
     product is called in for section 3  registration,  the  following data must  be submitted:  residue data from nature leaf
     and head lettuce, planted 21 days after the last  cf several foliar treatments of  a 4 Ib/gal EC formulation (only
     formulation with use directions  for lettuce) at 1 Ib  ai/A.  Aerial and ground applications should be represented in
     separate tests.   The tests must  take place  in  CA, the  only registered state.  If this product is to be used in
     other states, then appropriate geographical data  must be submitted.

11.  No residue data  hare been submitted in support of the  established tolerance for EPN residues in or on beans.
     Separate tolerances must be established for residues  of EPN in or on lima beans, snap beans and dry beans.  The
     soybean data provide adequate support  for the  3 ppm "bean" tolerance for residues in or on dry beans.  Data are
     required to support the 3 ppm tolerances for residues in or on snap beans and lima beans.  The data requested
     below for snap beans will be translated to  lima beans.  Residue data from nature snap beans harvested 21 days
     following several foliar applications  of the 3 Ib/gal  EC formulation, at  1.5 Ib ai/A are required.  Tests must
     include ( in separate tests) both aerial and ground applications, including the use of ULV equipnent.  The tests
     should take place in GA, TN,  and IA, representative states in which use of the high rate (1.5 Ib ai/A) is permitted.
     Data may be translated from snap beans to  lina beans  to support a tolerance for residues in or on lina beans.  Note
     if a crop group tolerance for beans is desired, additional data must be submitted for dry beans; data translated
     from soybeans, a representatire  ccmnodity  of the  Legune Vegetables Group, cannot be used to satisfy the data
     requirements for dried beans,  which is also a  representative  commodity.

     Residue data from snap bean cannery waste,  processed  from snap beans bearing neasurable, weathered residues
     are required.  Exaggerated rates may be necessary to  achieve  sich residue levels.  If residues are higher
     in cannery waste than in snap beans per se  an  appropriate feed additive tolerance must be proposed.

12.  Residue data are required from soybeans, harvested 21 days after the last of several applications of an EC formulation
     at 1 Ib ai/A»  Ihe data should reflect both aerial and ground applications, including the use of ULV equipment
     (separate tests).  Tests should  be  conducted in IL, NE, OH, and TN which represent the major soybean production and
     climatic regions of the U.S.

-------
                                                           -116-

                                                       TABLE A
                  GENERIC  E&TA REQUIREMENTS FOR CHEMICAL:  O-^thyl-O-p-nitrcpheryl pherylphosphonothipate     [EPN]

 §158.125 Residue Chemistry - Continued

     Residue data 'from the two soybean processed commodities, hulls and soapstock are required.  These products must be
     processed from nature soybeans  bearing measurable, weathered residues of EPN.  Exaggerated rates may be necessary to
     achieve such initial  residue levels.   If  residues  are found to concentrate  in hulls and soapstock, appropriate feed
     additive tolerances trust be  proposed.

     Data are adequate to  show that EPN  residues will not  concentrate  in soybean meal/ but will concentrate up to 5.5x in
     soybean oil.  A food  additive tolerance for EPN  residues in soybean oil that is approximately 6 times the tolerance
     for EPN residues in or on soybeans  must be proposed at the time the required residue data for soybeans are submitted
     to the Agency.

13.  Residue data from bean vines and bean hay harvested after the last of several applications of the 3 Ib/gal EC
     formulation, at 1.5 Ib ai/A  are required.  Tests must include both aerial and ground applications, including the
     use of ULV equipment  ( in separate  tests).   Vines  trust be sampled at intervals following the last treatment and
     hay must be harvested 21 days after the last treatment.  The tests should take place in GA, TN, and IA, repre-
     sentative states in which use of the high rate is  permitted.  Tolerances for residues in or on bean vines and hay
     must be proposed; a pregrazing  interval for bean vines must be proposed.  Alternatively, feeding and grazing
     restrictions may be proposed for bean  vines and  hay.

14.  Residue data are required from  soybean forage and  strav, harvested 21 days  after the last of several applications of
     an EC formulation at  1 Ib ai/A«  The data must reflect aerial and ground applications, including the use
     of ULV equipment (in  separate tests).   Tests should be conducted in IL, NE, OH, and TN, which represent the
     major soybean production and climatic  regions of the  U.S.  Tolerances for residues in or on soybean forage and
     straw mast be proposed.

15.  The submitted data are adequate to  support the established tolerance for tomatoes.  However, residue data from
     processed tomato products, including wet  pomace, dried pomace, puree, catsup and juice, processed from tomatoes
     bearing measurable, weathered residues are required to deteimine whether food/feed additive tolerances are
     needed.  Exaggerated  application rates may be necessary to achieve such initial residue levels.  Should
     concentrations of residues in processed products occur, appropriate food/feed additive tolerances must be
     proposed at the tine  these data are submitted to the  Agency.

16.  Residue data from whole sweet oranges, lemons, and grapefruit (representative crops of the Citrus Fruits group)
     harvested after the last of  several foliar  applications with an EC formulation (using aerial and ground
     application equipment, including UIV equipment,  in separate tests) at 2.25  Ib ai/A are required.  Tests must  also

-------
                                                           -117-

                                                       TABLE A
                  GENERIC  I&TA REQUIREMENTS FDR CHEMICAL:  <>ethyl-O-p-nitropheryl pherylphosphonothioate     [EPN]

 §158.125 Residue Chemistry - Continued


     reflect ground applications of  the  25% WP  at  0.5  Ib  ai/100 gal (>2000 gal/A).  The studies involving oranges and
     grapefruit should take place in CA  and PL;  those  involving lenons should take place in CA and AZ; these states
     represent the major U.S.  production areas  of  the  representative citrus crcps.  If the maximum residue values
     determined for any  two of the three crops  differ  by  more than a factor of five, separate tolerances nust be
     proposed for each of  the three  crcpsf  since a crop group tolerance would not be appropriate.   A maximum Ib ai/A
     rate to complement the 0.5 Ib ai/100 gal rate for ground applications of the 25% WP must be proposed.  Since it is
     unlikely that >2000 gal/A will  be applied,  wa  suggest a maximum rate cf 10 Ib ai/A.

     Residue data from the processed products of oranges, including dried pulp, oil, molasses, and juice processed
     from oranges bearing  neasurable,  weathered residues  are required.  Exaggerated rates may be required to achieve
     such residue levels.   If EPN is found  to concentrate in any of these products, appropriate food/feed additive
     tolerances must be  proposed at  the  tine these  data are submitted to the Agency.

17.  Residue data are required from  nature  apples  harvested 21 days after the last of several foliar ground applications
     (beginning at petal fall and continuing at 10-day intervals thereafter) of the 25% WP, and, in separate tests, an EC
     formulation at 0.375  Ib ai/100  gal  (800 gal/A).   Tests must also reflect both aerial and ground ULV application
     of an EC formulation  at 3 Ib ai/A (800 gal/A rate at 0.3751b ai/lQQ gal adjusted to maintain Ib ai/A rate).  The tests
     should take place in  WA, NY,  MI,  VA, and CA, which collectively account for approximately 70% of the U.S. apple
     production and the  major geographic areas  of  production.  A maximum Ib ai/A rate for applications of the 25% WP and EC
     formulations must be  proposed to  complement the registered 0.375 Ib ai/100 gal rate.  Since it is unlikely that more
     than 800 gal/A will be applied, wa  suggest a maximum rate cf 3 Ib ai/A.

     Residue data from dried pomace and  juice,  processed  from apples bearing neasurable,  weathered residues are  required.
     Exaggerated rates may be necessary  to  achieve  sxch residue levels.  If concentration of residues occurs upon pro-
     cessing, appropriate  food/feed  additive tolerances must be proposed at the time the data are submitted to the Agency.

18.  Residue data are required from  nature  pears harvested 14 days after the last of several foliar ground applications,
     beginning at petal  fall and continuing at  10-day  intervals thereafter, of the 25% WP and in separate tests, an EC
     formulation at 0.375  Ib ai/100 gal  (500 gal/A) •   Tests must also reflect both aerial and ground ULV applications of
     an EC formulation at  2 Ib ai/A  (500 gal/A  rate at 0.375 Ib ai/100 gal adjusted to maintain Ib ai/A rate).  Tests
     should be conducted in CA and WA, which collectively produce approximately 73% of domestic pears.  A maximum Ib ai/A
     rate for application  of the 25% WP  and EC formulations must be proposed to complement the registered 0.375 Ib ai/100
     gal rate.  Since it is unlikely that more  than 500 gal/A will be applied, we suggest a maximum rate of 2 Ib ai/A.

-------
                                                           -118-

                                                       TABLE A
                  GENERIC  i&TA REQUIREMENTS  FDR CHEMICAL:  O-ethyl-O-p-nitrcpneryl phenylphosphonothioate     [EPN]

 §158.125 Residue Chemistry  - Continued


19.  Residue data from peaches vd.ll support  the tolerance for apricots.

20.  Residue data are required fron nature sveet and sour cherries, harvested 21 days following the  last  treatment included
     in the following regimen:  (1) one  delayed dormant application using an EC formulation at 5 Ib ai/A  plus 1.5% oil;
     (2) foliar applications, beginning  at petal fall and continuing at 10-day intervals until 21 days  prior  to harvest,
     using (in separate tests):  (a) the 25% WP at 0.625 Ib ai/100 gal (ground application);  (b) the 25%  WP at 0.25  Ib
     ai/100 gal plus 1.5%  light medium oil (ground application); and,  (c) UIV applications (ground and  aerial, in
     separate tests) of an EC formulation at 3.75 Ib ai/A (maximum expected gal/A rate of 1000 at 0.375 Ib ai/100 gal
     adjusted to maintain  Ib ai/A rate)  and  two late sunner bark applications of the 5 Ib/gal EC at 1.5 Ib ai/A.
     In the case of ground-applied  high-volune foliar applications, 1000 gallons of spray mixture should  be applied  per
     acre.  The tests should be conducted in WA and MI which account for approximately 63% of U.S.  sweet  cherry production
     and approximately 84% of U.S.  sour  cherry production.  A maximum  Ib ai/A rate must be proposed to  complement the  Ib
     ai/100 gal rates for  (foliar)  applications.  Since it is unlikely that more than 1000 gal/A will be  applied, wa
     suggest maximum rates of 3.75  Ib  ai/A for the EC formulations and 6.25 Ib ai/A for the 25% WP,  unless the 1.5%  oil  is
     added, in which case  2.5 Ib ai/A  of the 25% WP would be the maximum rate.

21.  Residue data from peaches will support  the nectarine tolerance.

22.  Residue data are required for  mature peaches harvested 21 days following the last treatment in the following regimen:
     (i) one delayed dormant application using an EC formulation at 5  Ib ai/A plus 1.5% oil;  (ii) foliar  applicat
     beginning at petal fall and continuing  at 10-day intervals until 21 days prior to harvest using (in  separate tests):
     (a) the 25% WP at 0.625 Ib ai/100 gal (ground application); (b) the 25% WP at 0.25 Ib ai/100 gal plus 1.5% light
     medium oil (ground application);  and, (c) ULV applications (ground and aerial, in separate tests)  of an  EC formula-
     tion at 2 Ib ai/A (maximum expected gal/A rate of 500 adjusted to naintain Ib ai/A rate);  (iii) two late-summer
     bark applications at  1.5 Ib ai/A  using  the 5 Ib/gal EC.  In the case of ground-applied high-volume foliar
     applications, 500 gallons of spray  mixture should be applied per acre.  Ihe tests should be conducted in CA  and SC
     which produce approximately 74% of  U.S. peaches.  The data required here will also be used for assessment of the
     tolerance for residues  of EPN  in  or on  nectarines and apricots.  A maximum Ib ai/A rate must be proposed to
     complement the Ib ai/100 gal rates  for  (foliar) applications.  Since it  is unlikely that more than 500 gal/A will
     be applied, wa suggest  a maximum  rate of 2 Ib ai/A for the EC formulations and 3.1 Ib ai/A for the 25% WP,
     unless 1.5% oil is added in which case  1.25 Ib ai/A of the 25% WP would be the maximum rate.

23.  Residue data are required from nature plums, harvested 21 days following the last treatgtient included in the following
     regimen: (i) one delayed dormant  application using an EC formulation at 5 Ib ai/A plus 1.5% oil; (ii) foliar

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                                                           -119-

                                                       TABLE A
                 GENERIC  CATA REQUIREMENTS FDR CHEMICAL:  0-ethyl-CHp-nitropheryl pherylphosphonothioate     [EPN]

 §158.125 Residue Chemistry  - Continued

     applications,  beginning at petal fall  and continuing at 10-day intervals until 21 days prior to harvest,  using  (in
     separate tests):   (a) the 25% WP at 0.625 Ib ai/100 gal (ground application); (b) the 25% WP at 0.25 Ib ai/100  gal
     plus 1.5% light medium  oil (ground  application); and, (c) ULV applications (ground and aerial, in separate  tests) of
     an EC fonnulation at  2  Ib ai/A  (maximum expected gal/A rate of 500 adjusted to maintain Ib ai/A rate); and, (iii) two
     late-summer bark  applications of the 5 Ib/gal EC at 1.5 Ib ai/A.  In the case.of ground-applied high-volume foliar
     applications,  500 gallons of spray  mixture should be applied per acre.   The tests should be conducted in OR and MI
     which account  for approximately 69% of U.S. plum production.  A maximum Ib ai/A rate must be proposed to complement
     the Ib ai/100  gal rates for (foliar) applications.  Since it is unlikely that more than 500 gal/A will be applied, ve
     suggest maximum rates of 2 Ib ai/A  for the EC formulations and 3.1 Ib ai/A for the 25% WP, unless 1.5% oil  is added
     in which case  1.25 Ib ai/A if the 25%  WP
     would be the maximum rate.

     Residue data from dried prunes, processed from plums bearing neasurable, weathered residues are required.
     Exaggerated rates may be required to achieve such residue levels.  If residues are found to concentrate in  the
     dried fruit, an appropriate food additive tolerance must be proposed at the time the data are submitted to  the
     Agency.

24   Residue data from mature grapes, harvested 21 days after the last cf several foliar applications made, in
     separate tests, aerially (including ULV applications) and with ground application equipment (including ULV
     and high volume applications) using an EC fomulation at 0.25 Ib ai/100 gal (250 gal/A) for high-volume
     applications and  at 0.63 Ib ai/A (UIV  applications).  High-volume foliar application tests (ground-applied)
     with the 25% WP must  also be made at 0.25 Ib ai/100 gal rate at a maximum expected gal/A of 250 to maintain
     the correct rate  of active  ingredient  per acre.  The applications should be made at 10-day intervals
     beginning at bloom.   A  maximum expected ai/A rate for high-volume applications must be proposed.  Since the
     maximum expected  gal/A  rate is 250,  we suggest that a maximum rate cf 0.63 Ib ai/A be proposed.

     Residue data from raisins,  raisin waste, juice, wat pomace and dried pomace processed fron grapes bearing
     measurable, weathered residues are  required.  Exaggerated rates may be necessary to achieve such residue
     levels.  If residues  concentrate in an/ of these processed products, appropriate food/feed additive
     tolerances must be proposed at the  tine the data are submitted to the Agency.

25.  Residue data from nature almond nutmeats and corresponding hulls, harvested 21 days after the last of several
     foliar ground  applications of an EC formulation at, in separate tests,  0.25 Ib ai/100 gal (800 gal/A) using

-------
                                                           -120-

                                                       TABLE A
                  GENERIC DATA RETIREMENTS FOR CHEMICAL:  Oethyl-O-p-nitrcphenyl phervlphosphDnothioate     [EPN]

 §158.125 Residue Chemistry - Continued


     high-volume ground equipnent and 2  Ib ai/A using UIV ground equipment are required.  The data should also
     reflect UIV aerial applications of  the EC at 2  Ib  ai/A.  (The  Ib ai/A rate for UIV applications was calculated from
     the maximum'expected gal/A rate (800)  at 0.25 Ib ai/100 gal to maintain the correct rate of active ingredient per
     acre.) The tests should take place  in CA where  the majority of almonds are produced.  A maximum Ib ai/A rate for
     foliar applications to complement the maximum registered Ib ai/100 gal rate (0.25) should be proposed.  Since
     it is unlikely that more than 800 gal/A will be applied, vte suggest that a maximum rate of 2 Ib ai/A be
     proposed.

26.  Residue data from pecans harvested  21 days after the last of several foliar applications with the 25% WP and, in
     separate tests,  an EC fomiulation,  at 0.5 Ib ai/100 gal (1000  gal/A) are required.  The data should reflect, in
     separate tests,  both ground and aerial UIV applications of an  EC formulation at 5 Ib ai/A.  (The Ib ai/A rate for
     UIV applications was calculated from the maximum expected gal/A rate (1000) at 0.5 Ib ai/100 gal to maintain the
     correct rate of  act ire ingredient per  acre.)  The  tests should take place in GA and tM which together produce
     approximately 70% of the U.S.  pecan crop.   A maximum Ib ai/A rate for foliar applications to complement the
     maximum registered Ib ai/100 gal rate (0.5) must be proposed.  Since it is unlikely that more than 1000 gal/A
     will be applied, wa suggest that a  maximum rate of 5 Ib ai/A be proposed.

27.  Residue data are required from nature walnuts,  harvested 21 days after the last of several applications of the 4
     Ib/gal EC at 3.5 Ib ai/A, beginning at petal  fall  and continuing at 10-day intervals using, in separate tests,
     aerial and ground application equipnent, including tests using ULV equipnent.  Data reflecting the 25% WP are not
     required since the maximum expected Ib ai/A rate,  based on 1000 gal/A, for this formulation is much lower than 3.5
     Ib ai/A.  The tests should take place in CA where  the majority of the walnuts are grown.  A maximum Ib ai/A rate for
     high volume applications must be proposed to complement the maximum Ib ai/100 gal rate.

28.  Data are adequate to support the established  tolerance for residues of EPN in or on corn.  However, data are required
     to determine if residues of EPN concentrate in  field corn processed products.  Therefore, residue data from corn
     processed products, including milled products,  crude oil and refined oil processed from corn grain bearing neasurable,
     weathered residues are required. Exaggerated rates may be required to achieve sich residue levels. If residues are
     found to concentrate, appropriate food/feed additive tolerances must be proposed at the time these data are submitted
     to the Agency.

29.  Residue data from sweet corn forage and field corn forage, foddsr and silage harvested after the last of several
     foliar applications of an EC and in,  separate tests, a G and a WP at 0.75 Ib ai/A are required.  The tests should
     include aerial and ground ULV applications of an EC formulation.  Forage trust be collected at intervals following the

-------
                                                            -121-

                                                        TABLE  A
                  GENERIC EATA REQUIREMENTS FDR CHEMICAL:   CKsthyl-O-p-nitrophervl  pherylphosphonothioate     [EPN]

 §158.125 Residue Chemistry - Continued

     last application; a pregrazing interval rtust be proposed.   Fodder and silage must be harvested  14 days  after the last
     treatment.   Tests should take place in IA, INr  FL,  MN,  CA,  NY, and TN which collectively represent all  of the major
     areas of the U.S. where field and sweet corn foliage would be used for forage,  fodder or  silage.

30.  The submitted data are adequate to support the  established  tolerance  for residues  of EPN in or on cottonseed.  The
     data are also adequate to show that concentration of  residues does not occur upon processing  cottonseed into rteal,
     but does occur,  up to approximately 40x, upon processing  into oil.  Therefore,  a  food additive tolerance for
     residues of EPN in cottonseed oil trust be  proposed at the time  the data on cottonseed hulls and soapstock are
     submitted.   Wfe suggest that  a tolerance of 20 ppm be proposed.   In addition, the  following data are  required to
     determine if EPN residues concentrate in two other processed predicts,  hulls and  soapstock.   Residue data from
     cottonseed hulls and soapstock, processed  fron  cottonseed bearing  neasutrable,  weathered residues  are required.
     Exaggerated rates may be necessary to achieve such initial  residue levels.  If  residues are found to concentrate in
     either product, appropriate  feed additive  tolerances nust be proposed at the tine  these data  are  submitted  to the
     Agency.

31.  Residue data from nature olives harvested  frcm  trees which  received several foliar applications of the  4 or 5 Ib/gal
     EC at 12 lb ai/A and, in separate tests, of the 25% WP at 0.25  Ib ai/100 gal puls  1.5% light  medium oil (800 gal of
     spray/A).  The last application should be  made  on July 15.   Residue data reflecting both  aerial and ground  applica-
     tions, including the use of  ULV equipment,  with an EC  formulation  rrust be submitted.   Only ground application data
     are required for the 25% WP.  Tests must be conducted  in CA.

     Residue data from olive oil  produced frcm  olives bearing  measurable,  waathered  residues of EPN are required.
     Exaggerated rates may be necessary to achieve sich initial  residue levels.  If  concentration  of residues does take
     place, an appropriate food additive tolerance mast  be  proposed at  the tine these  data are submitted to  the  Agency.

32.  There are no direct animal treatments for  EPN.   However,  tolerances are established on raw agricultural commodities
     with registered uses which may either be fed directly  (unprocessed) or processed  into commodities which may be fed
     to livestock.  Since additional data are required to  support tolerances for residues of EPN in or on many of these
     raw agricultural ccmitDdities and data are  needed to determine whether concentration of residues occurs  on processing,
     we are unable to estimate the maximum expected  intake  of EPN residues by cattle,  poultry, or  swine at this  time.
     Upon receipt of  the requested animal metabolism data,  and data pertaining to residues in major feed  items,  the
     adequacy of the available data will be assessed and specific data requirements regarding  residues in animal products
     will be determined.

-------
                                                           -122-
                                                       TABLE A
                GENERIC DATA REQUIREMENTS FDR CHEMICAL:  C>-ethyl-O-p-nitrcphen/l pherylphosphonothioate     [EPN]
Data Requirement
           1      Use  2
Composition     Pattern
             Does EPA Have
             Data To Satisfy
             This Require-
             ment?  (Yes, No
             or Partially)
                    Bibliographic
                      Citation
Mast Additional Data
Be Submitted Under
FTFRA § 3(c)(2)(B)?
Time Frane for Data
Submission ^
 §158.130 Environmental Fate

  DEGRADATION STUDIES-LAB;
  161-1 - Hydrolysis

  Photodegradation

  161-2 - In water

  161-3 - On soil

  161-4 - In Air

  METABOLISM STUDIES-LAB;

  162-1 - Aerobic Soil

  162-2 - Anaerobic Soil
TGAI or PAIRA   A,B,




1GAI or PAIRA   A,B,

TGAI or PAIRA   A

TGAI or PAIRA   A




TGAI or PAIRA   A,B,

TGAI or PAIRA   A
             No




             No

             No

             No




             No

             No
                                        Yes
           9 Months
Yes
Yes
No
Yes
Yes
9 Months
9 Months

27 Months
27 Months
  162-3 - Anaerobic Aquatic


  162-4 - Aerobic Aquatic

  MOBILITY STUDIES:
TGAI or PAIRA   -
TGAI or PAIRA   -
  163-1 - Leaching and           TGAI  or PAIRA  A,B,
          Adso rp t ion/Deso rp t ion
  163-2 -Volatility (Lab)

  163-3 - Volatility (Field)
    TEP

    TEP
A

A
No


No




No


No

No
No


No




Yes


No

No
                                                                                12 Months

-------
                                                         -123-
                                                     TABLE A
              GENERIC DATA REQUIREMENTS FDR CHEMICAL:  O-ethyl-O-p-nitropheryl pherylphosphonothioate     [EPN]
1 Use 2
Data Requirenent Composition Pattern
Does EPA Have
Data To Satisfy
This Require-
ment? (Yes, No
or Partially)
Mist Additional Data
Be Submitted Under
Bibliographic FIFRA § 3(c)(2)(B)?
Citation Time Frame for Data
Submission 3
§158.130 Environmental Fate - Continued
DISSIPATION STUDIES-FIELD:
164-1
164-2
164-3
164-4
- Soil TEP A,B
- Aquatic (Sedinent) TEP
- Forestry TEP
- Combination and
No
No
No
No
Yes 27 Months
No
No
No
         Tark Mixes

164-5 - Soil, Long-tern

ACCUMULATION STUDIES;

165-1 - Rotational Crops
         (Confined)

165-2 - Rotational Crops
         (Field)

165-3 - Irrigated Crops

165-4 - In Fish

165-5 - In Aquatic Non-Target
         Organisms
    TEP       A




   PAIRA      A


    TEP       A


    TEP

TGAI or PAIRA A,B

    TEP       A
No




No


No


No

No

No
Yes4



Yes


Yes5


No

Yes

No
50 Months



39 Months


50 Months
12 Months

-------
                                                          -124-

                                                      TABLE A
              GENERIC DATA REQUIREMENTS FDR CHEMICAL:   0-ethyl-O-p-nitrop hen/1  pherylphosphonothioate     [EPN]

 §158.130 Environmental Fate - Continued

1.  Camposition:  TGftI = Technical grade cf the active ingredient;  EMRA = Pure active  ingredient,  radio-labelled;
    TEP = Typical end-use product.

2.  The use patterns are coded as follows:   A^Terrestrial, Pood Crop; B=Terrestrial, Non-Food; C=Aquatic,  Food Crop;
    D=Aquatic, Non-Food; E=Greenhcuse,  Food Crop; F=<3reenhcuse, Non-Food;  G=Forestry; H=Doitestic Outdoor;  I=Indoor.

3.  Data must be submitted within the indicated time frane.  The beginning date for these time  frames is March 26,  1987,
    the date of the Agency's most recent Data Call In Notice calling in these data.
       9 Month Due Date is      DECEMBER 26, 1987	;   12 Month Due Date is	MARCH 26,  1988	;
      15 Month Due Date is      JUNE 26, 1988	;   27 Month  Due Date is 	JUNE  26, 1989	;
      39 Month Due Date is      JUNE 26, 1990	;   50 Month Due Date is	MAY  26,  1991	.

4.  Based on the aerobic soil netabolism study or field dissipation studies, if 50%  dissipation  is  reached by  the time
    of subsequent applications no long-term study is required.

5.  This study is required only if significant residues of concern  are  found in the  confined study.

-------
                                                         -125-
                                                       TABLE A
                      GENERIC  DATA REQUIREMENTS FOR CHEMICAL:  O-ethyl-O-p-nitrcpheryl pherylphosphonothioate     [EPN]
1 Use
Data Requirement Composition Pattern
Does EPA Have
Data To Satisfy
2 This Require- Bibliographic
nent? (Yes, No Citation
or Partially)
Mist Additional Data
Be Submitted Under
FIFRA § 3(c)(2)(B)?
Time Frane for Data
Submission^
§158.135 Toxicology
ACUTE TESTING:
81-1
81-2

81-3

81-4
81-5
81-6
81-7

- Acute Oral Toxicity - Rat
- Acute Dental Toxicity
- Rabbit
- Acute Inhalation Toxicity
- Rat
- Eye Irritation - Rat
- Dermal Irritation - Rat
- Dermal Sensitization
- , Delayed
Neurotoxicity - Hen
TGAI
TGAI

TGAI

TGAI
TGAI
TGAI
TGAI

A
A

A

A
A
A
A

Yes
Yes

Yes

Yes
Yes
No
Yes

00100099
00145678

00057028

00100099
00100099
-
00159372

No
No

No

No
No
Yes 9 Months
No

SUBCHRONIC TESTING:
82-1


82-2
82-3
82-^
- 90-Day Feeding :
- Rodent, and
- Non-rodent (Dog) -,.
' ' A
- 21-Day Dental - Rabbit
- 90-Day Dermal - Rat
- 90-Day Inhalation:
TGAI


TGAI
TGAI
TGAI

A
A
A
A


Yes
Yes
Yes
No


00158874
00158890
00152760
-


No
No
No
No4

        - Rat

82-5 - 90-Day Neurotoxicity:
        - Hen
TGAI
                         Yes
                         Yes
00161799
00003945
No
Mb

-------
                                                          -126-
                                                        TABLE A
              GENERIC D&TA REQUIREMENTS FOR CHEMICAL:   C>-ethyl-O-p-nitrcphenyl pherylphosptonothioate     [EPN]
Does EPA Have Must Additional Data
Data To Satisfy Be Submitted Under
1 Use 2 This Require- Bibliographic FIFRA § 3(c) (2) (B)?
Data Requirement Composition Pattern nent? (Yes, No Citation Time Frane for Data
or Partially) Submission
§158.135 Toxicoloqy - Continued
CHRONIC TESTING:
83-1 - Chronic Toxicity - 1GAI
2 species:
- Rodent, and A No
- Non-rodent (Doq) A No
83-2 - Oncogen icity - TGAI
2 species:
- Rat (preferred), and A No
- Mouse (preferred) A No
83-3 - Teratogsn icity - TGAI
2 species:
- Rat A No
- Rabbit A No
83-4 - Reproduction - Rat TGAI A No
2-ganeration
MUTAGENICITY TESTING
84-2 - Gene Mutation (Ames Test) TGAI A Yes
84-2 - Structural Chromosomal TGAI A Yes
Aberration
Yes5
Yes5
Yes6
Yes6
00162934 No
00163019 No
Yes7
00153511 No
00160618
00153510 No
00153509
84-2 - Unscheduled DNA
         Synthesis
TGAI
Yes
001535089
No

-------
                                                         -127-
GENERIC D\TA REQUIREMENTS FDR CHEMICAL:
                                                       TABLE A
                                                      O-ethyl-CHp-nitrcphen/l pherylphosphonothioate     [EPN]
Does EPA Have Must Additional Data
Data To Satisfy Be Submitted Under
1 Use 2 This Require- Bibliographic FEFRA § 3(c) (2) (B)?
Data Requirenent Composition Pattern nent? (Yes, No Citation Time Frane for Data
or Partially) Submission 3
§158.135
Toxicology - Continued


SPECIAL TESTING
85-1 -
85-3 -
85-X -
General Metabolian EAI or PAIRA A Partial
Dermal Absorption PAIRA A No
Acute Delayed Neuro- TGAI A Yes
00158920 Yes8
Yes9
00160200 No10
24 Months
12 Months

       toxicity - Mechanism
       Recovery - Hen

85-Y - Neurotoxicity in Hens
       Single Dose NOEL
                    TGAI
No
12 Months

-------
                                                           -128-

                                                      TABLE A
               GENEREC DATA REQUIREMENTS FOR CHEMICAL:   O-ethyl-0-p-nitrqphen/l pherylphosphonothioate  >    [EPN]

 §158.135 Toxicology - Continued

 1.  Composition:  EAI = Pure active  ingredient;  BVIRA = Pure active  ingredient, radio-labelled; Choice = Choice of several
     test substances determined on a  case-by-case basis.

 2.  The use patterns are coded as  follows:   A=Terrestrial, Food Crcp; Bterrestrial, Non-Food; C=Agautic, Food Crop;
     D=Aquatic, Non-Food; E=Greenhouse,  Food Crop; F=Greenhcase, Non-Food; G=Forestry; H=Donestic Outdoor; I=Indoor.

 3.  Data must be submitted within  the indicated  time  frame.  The  beginning date for these time frames is March 26, 1987,
     the date of the Agency's most recent Data Call In Notice calling in these data, except where indicated otherwise.
         9 Month Due Date is	DECEMBER 26, 1987      ;  12 Month Due Date  is      MARCH 26, 1988	;
        24 Month Due Date is      MARCH 26, 1989	.

 4.  Based on expected exposure patterns this study  is not  required.

 5.  The chronic feeding studies are  due by  May 1, 1989.

 6.  The onccgenicity studies are die by October  1988.

 7.  The 2-ganeration reproduction study is  due November  1, 1987.

 8.  Male rats must be treated with the same dose used for  females.  Metabolites must be  identified.
     Potential excretion in bile trust be inrestigated.

 9.  Contact EPA for protocol.

10.  The only requirement for this  previously submitted  study was  a revaluation of the spinal cord slides
     in groups 7, 8,  9 and 10 in order to determine if the hens showing signs  of neurotoxicity can be
     distinguished by the pattern cf  abnormalities  in  the cord.  This ree/aluation has been completed.
     There are no further requirements for this study.

11.  A single dose study in hens to  determine a NOEL for delayed neurotoxicity by observation and histcpatnology.
     20 hens per dose to allow sacrifice of  10 hens per dose at 21  and 40 days post dose.

-------
                                           -129-

                                        TABLE  A
GENERIC DATA REQUIREMENTS FDR CHEMICAL O-ethyl  0-p-nitrcphervl phenylphosptonothioate
[EPN]
Does EPA Have Must Additional Data
Data To Satisfy Be Submitted Under
I/ Use y This Require- Bibliographic FIFRA § 3(c) (2) (B)?
Data Requirenent Composition Pattern nent? (Yes, No Citation Time Frane for Data
or Partially) Submission 3/
§158.140
132-1
132-1
133-3
133-4
§158.142
201-1
201-1
Reentry Protection
- Foliar Dissipation TEP A Yes 00162999
00163515
- Soil Dissipation TEP A No
- Demval Exposure TEP A No
- Inhalation Exposure TEP A No
Spray Drift
- Droplet Size Spectrum TEP A No
- Drift Field Evaluation TEP A No
No 27 Months
No
No
No
Yes4 12 Months
Yes4 12 Months

-------
                                                            -130-

                                                         TABLE A
                 GENERIC DATA REQUIREMENTS EDR CHEMICAL  O-ethyl O-p-nitrcpheivl pherylphosphonothioate      [EPN]
Data Requirement
i/
Composition
Use 2/
Pattern
Does EPA Have
Data To Satisfy
This Require-
nent? (Yes, No
or Partially)
Bibliographic
Citation
Mast Additional Data
Be Submitted Under
FIFRA § 3(c)(2)(B)?
Time Frane for Data
Submission •*/
§158,140  Reentry Protection  continued

1. Composition: TEP = Typical end-use product.

2. The use patterns are coded as follows:  A=Ter res trial,  Food Crop; B=Ter res trial, Non-Food; C=Aquatic, Food Crop;
   D=Aquatic, Non-Food; E=Q:eenhcuse,  Food Crop; F=Greenhouse, Non-Food; OForestry; H=Domestic Cutdoor; I=Indoor.

3. Data must be submitted within the indicated  time  frame.   The  beginning  date  for these time frames  is March 26, 1987,
   the date of the Agency's most recent  Data Call  In Notice  calling in these data.
         12 Month Due Date is      MARCH 26,  1988	;   27 Month Due Date is	JUNE 26, 1989	.

4. The spray drift droplet spectrum and  field evaluation  may be done together in order to evaluate the drop spectrums
   that are associated with actual field use patterns.

-------
                                           -131-

                                         TABLE A
GENERIC DATA RBQUIREMENTS FOR CHEMICAL O-etbyl-O-p-nitrcpheryl  phen/lphosphonothioate
[EPN]
1 Use
Data Requirement Composition Pattern
§158. 145 Wildlife and
Aquatic Organisms
AVIAN AND MAMMALIAN TESTING
71-1 - Acute Avian Oral Toxicity TGAI
- Upland Game Bird, and
- Waterfowl
71-3 - Wild Mammal Toxicity TGAI
71-4 - Avian Reproduction TGAI
- Upland Game Bird, and
- Waterfowl
71-5 - Simulated Field Testing TEP
- Mammals, and
- Birds
- Actual Field Testing TEP
- Mammals, and
- Birds

A
A
A
A
A
A
A
A
A
A
Does EPA Have Must Additional Data
Data To Satisfy Be Submitted Under
2 This Require- Bibliographic FIFRA § 3(c) (2) (B)?
nent? (Yes, No Citation Time Frame for Data
or Partially) Submission 3

Yes
Yes
Yes
No
No
No
No
No
No
No
•
00111931 ;05000975 No
00022923 No
00077299
00022923 No
No
Yes4 24 months
Yes4 24 nonths
Reserved^
Reserved^
Reserved^
Reserved ^

-------
                                                           -132-
                                                         TABLE A
                 GENERIC  D\TA REQUIREMENTS  FDR CHEMICAL 0-ethyl-O-p-nitropheryl pherylphosphonothioate      [EPN]
Data Requirenent
Composition
  Use  2
Pattern
Does EPA Have
Data To Satisfy
This Require-
nent?  (Yes, No
or Partially)
Bibliographic
  Citation
Mist Additional Data
Be Submitted Under
FTFRA § 3(c)(2)(3)?
Time Frane for Data
Submission ^
§158.145 Wildlife and
 Aquatic Organisms - Contirued

  AQUATIC ORGANISM TESTING

  72-1 - Freshwater Fish Toxicity    TGAI
          - Coldwater Fish Species,
            and
          - Warmwater Fish Species

  72-2 - Acute Toxicity  to
          Freshwater Invertebrates
    TGAI
  72-3 - Acute Toxicity  to           TGAI
          Estuarine and  Marine
          Organ isms
          - Fish

          - MDllask

          - Shrimp

  72-4 - Fish Early Life Stage,      TGAI
         and - Aquatic Invertebrate
         Life-Cycle
         a.  Freshwater  fish
         b.  Shrimp
         c.  Freshwater  invertebrate
                              Yes
                                 00100093
                                        No
A
A
A
A
A
A

Yes
Yes
Yes
Yes
Yes

No
Yes
No
00100093
00100093 ,-05009242
00002875;00085219
00066341
00066341
00066341

00066341
No
No
No
No
No

Yei
No
Ye:
                                                                    Yes6 15 months
                                                                    No
                                                                    Yes6 15 months

-------
                                                        -133-
                                                      TABLE A
              GENERIC  EATA REQUIREMENTS FDR CHEMICAL O-ethyl-O-p-nitrophenyl phenylphosphonothioate
                                                                       [EPN]
Does EPA Have Mast Additional Data
Data To Satisfy Be Submitted Under
1 Use 2 This Require- Bibliographic FTFRA § 3(c) (2) (B)?
Data Requirement Composition Pattern nent? (Yes, No Citation Time Frane for Data
or Partially) Submission •*
§158.145
Aquatic
72-5
72-6



Wildlife and
Organisms - Continued
-Fish - Life-Cycle TGAI A Yes
- Aquatic Organism TGAI, PAI OR
Accumulation Degradation
Product
- Crustacean A No
- Fish A No
- Insect Nymph A No
- Mollusk A No

00066341 No
7
7
7
7
72-7 - Simulated Field Testing
         - Aquatic Organisms

     - Actual Field Testing
         -Aquatic Organisms
TEP
                         No
                         No
Yes8   24 Months
Yes8   48 Months

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                                                          -134-

                                                     TABLE A
              GENERIC DATA REDUTREMENTS FOR CHEMICAL:   Oeth/l-O-p-nitrcpheryl pherylphosphonothioate      [EPN]

§158.145 Wildlife and Aquatic Organisms - Continued

1.  Composition:  1GAI = Technical grade of the active  ingredient;  E&I = pure active  ingredient;
    TEP = Typical end-use product;

2.  The use patterns are coded  as follows:   A=Terrestrial, Food Crop; B^Terres trial, Non-Food Crop; C=Aquatic, Food Crop;
    D=Aquatic, Non-Food; E=<3reenhcuse,  Food Crop;  F=<3reenhouse, Non-Food; G=Forestry; H=Domestic Outdoor; I=Indoor.

3.  Data roust be submitted within the indicated time  frame.   The  beginning  date  for these  time franes  is March 26, 1987,
    the date of the Agency's most recent Data Call In Notice  calling in these data.
      15 Month Due Date is       JUNE 26, 1988	;   24 Month Due Date is	MARCH 26, 1989	.
      48 Month Due Date is	March 26,  1991	.

4.  Data are required to support repeated applications  to  cotton.

5.  This data requirement is reserved pending receipt and  evaluation of certain  environmental fate data requirements and
    review of required avian reproduction study.

6.  It is expected that aquatic environments will  be  exposed  frcm the use on cotton, corn  and soybeans to the extent
    that this study is required.

7.  See Table A, data requirements for Accumulation Studies under Section 158.130, 165-4 and 165-5.

8.  Residue monitoring in aquatic environments adjacent to cotton and corn  producing areas are required.  In lieu of
    monitoring, a mesoccsm study may  be submitted. An  acceptable protocol  nust  be submitted prior to  initiating these
    studies.  Acceptable environmental fate data,  when  submitted, may alter these requirements.

-------
                                                           -135-

                                                           TABLE A
                GENERIC DATA REQUIREMENTS FDR CHEMICAL:   O-ethyl-O-p-nitrcpheryl phen/lphosphonothioate     [EPN]
1 Use 2
Data Requirement Composition Pattern
§158.150 Plant Protection
121-1 - TARGET AREA
PHYTOTOXICITY EP
NONTARGET AREA PHYTOTOXICITY
Does EPA Have
Data To Satisfy
This Require- Bibliographic
nent? (Yes, No Citation
or Partially)
3
Mist Additional Data
Be Submitted Under
EIFRA § 3(c)(2)(B)?
Time Frame for Data
Submission

          TIER I

 122-1 - Seed Germination/
         Seedling Emergence
TGAI
122-1
122-2
123-1
123-2
123-3
124-1
124-2
- Vegetative Vigor
- Aquatic Plant Growth
TIER II
- Seed Genni nation/
Seedling Emergence
- Vegetative Vigor
- Aquatic Plant Growth
TIER III
- Terrestrial Field
- Aquatic Field
TGAI
TGAI
TGAI
TGAI
TGAI
TEP
TEP
3
3
3
3
3
3
3
1.  Composition:   TGAI = Technical  grade of  the active  ingredient; TEP = Typical end-use  product.   EP = End-use  product.

2.  The use patterns are coded as follows:   A=Terrestrialr  Food Crop;  B terrestrial, Non-Food Crop; C=Aquatic,  Food Crop;
    D=Aquatic, Non-Food; E=Greenhcuse,  Food  Crop; F=<3i:eenhojse, Non-Food;  G=Forestry; H=Domsstic Outdoor; I=Indoor.

3.  These data are net required in accordance with §158.150.

-------
              GENERIC EATA REQUIREMENTS EDR CHEMICAL:
   -136-

   TABLE A
O--ethyl-O-p-nitrcphen/l phen/lphosphonothioate
[EPN]
1 Use 2
Data Requirenent Composition Pattern
§158.155 Nontarget Insect
NONTARGET INSECT TESTING -
POLLINATORS:
141-1 - Honey bee acute TGAI A
contact toxicity
141-2 - Honey bee - toxicity TEP A
of residues on foliage
141-4 - Honey bee subacute (Reserved) ^
feeding study
141-5 - Field testing for TEP A
Does EPA Have
C&ta To Satisfy
This Require- Bibliographic
itent? (Yes, No Citation
or Partially)
Yes 00036935
No
No
Mist Additional Data
Be Submitted Under
FIFRA § 3(c)(2)(B)?
Time Frane for Data
Submission 3
No
Yes4 15 Months
No6
         pollinators

1.  Composition:  TGAI = Technical grade of  the active  ingredient; TEP = Typical  end-use product.

2.  The use patterns are coded as follows:   A=Terrestrial,  Food Crop; B=Terrestrial, Non-Food; C=Aquatic, Food Crop;
    D=Aquatic, Non-Food; E=Greenhcuse,  Food  Crop; F=Greenhouse, Non-Food;  G=Forestry; H=Domestic Outdoor; I=Indoor.

3.  Data most be submitted within the  following tine  frame.  The beginning date for these tine franes is March 26,  1987,
    the date of the Agency's most recent Data Call  In Notice calling  in these data.
      15 Month Due Date is      JUNE 26, 1988	.

4.  Data from the acute contact test indicate high  toxicity, therefore, data on residual toxicity are required.

5.  Requirenent reserved pending the developnent of test methodology.

6.  The data reviewed do not indicate the need for  a  field study.

-------
                                                            -137-

                                                              TAELE  A
                 GENERIC DATA REQUIREMENTS FDR CHEMICAL O-ethyl 0-p-nitrcphenyl phenylphosphonothioate       [EPN]

                                                              Does EGA Have                           Mast Additional Data
                                                              Data To Satisfy                         Be Submitted Under
                                            1      Use  2      This Require-       Bibliographic       FIFRA  § 3(c) (2) (B)?
Data Requironent                 Composition     Pattern       nent?   (Yes, No       Citation          Tirae Frane  for Data
	or  Partially)	Submission  3	
§158.155 Nontarget Insect - Continued

  NONTARGET INSECT TESTING -
  AQUATIC INSECTS;

  142-1 - Acute toxicity to      (Reserved)
           aquatic insects

  142-1 - Aquatic insect         (Reserved)
           life-cycle study

  142-3 - Simulated or actual    (Reserved)
           field testing for
           aquatic insects

  143-1 - NONTARGET INSECT       (Reserved)
          TESTING - PREDATORS
  thru    AND PARASITES

  143-3
  1.  Composition:   TGAI = Technical  grade  of the active ingredient; TEP = Typical end-use product.
  2.  The use patterns are coded as follows:  A=Terrestrial,  Food Crop; B=Terrestrial, Non-Food; C=Aquatic, Food Crop:
      D=Aqautic,  Non-Food; E=Greenhcuse, Food Crop; F=Greenhcuse, Non-Food; G=Forestry; H=Donestic Outdoor; I=Indoor.

-------
                                                           -138-
                                                       TABLE B
                PRODUCT SPECIFIC  DATA REQUIREMENTS EOR MANUFACTURING-USE PRODUCTS CONTAINING CHEMICAL:
                                     O-ethyl O-p-nitrqphenyl phenylphcsphonothioate     [EPN]
Data Requirement
Conposition
Does EEA Have
Data To Satisfy
This Require-
nent?  (Yes,  No
or Partially)1
Bibliographic
  Citation1
Mist Additional Data
Be Submitted Under
FIFRA § 3(c)(2)(B)?
Time Frane for Data
Submission ^
§158.120 Product Chemistry

  Product Identity!

  61-1 - Product Identity and Disclosure    MP
          of Ingredients

  61-2 - Description of Beginning Materials  MP
          and Manufacturing Process

  61-3 - Discussion of Formation of          MP
          Impurities

  Analysis and Certification  of  Product
  Ingredients

  62-1 - Preliminary Analysis               MP

  62-2 - Certification of Limits            MP

  62-3 - Analytical  Methods to Verify        MP
          Certified  Limit

  Physical and Chemical Characteristics

  63-2 - Color                              MP

  63-3 -Physical State                      MP

  63-4 -Odor                               MP
                           N/A


                           N/A


                           N/A
                           N/A

                           N/A

                           N/A
                           N/A

                           N/A

                           N/A
                                         Yes
                                         Yes
                                         Yes
                              6 Months


                              6 Months


                              6 Months
                                         Yes     12 Months

                                         Yes     12 Months

                                         Yes     12 Months
                                         Yes      6 Months

                                         Yes      6 Months

                                         Yes      6 Months

-------
                                                         -139-
                                                     TABLE B
              PRODUCT SPECIFIC EATA REQUIREMENTS FDR MANUFACTURING-USE PRODUCTS CONTAINING CHEMICAL:
                                   Q-ethyl O-p-nitrcphenyl phenylphasphonothioate     [EPN]
Data Requirenent Composition
Does EBV Have
Data To Satisfy
This Require-
ment? (Yes, No
or Partially)1
Mist Additional Data
Be Submitted Under
Bibliographic FIFRA § 3(c)(2)(B)?
Citation 1 Time Frane for Data
Submission 2
§158*120 Product Chemistry (Continued)
Physical and Chemical Characteristics
(Continued)
63-7 -
63-12
63-14
63-15
63-16
63-17
63-18
63-19
63-20
- Density, Balk Density, or
Specific Gravity
-pH
- Oxidizing or Reducing
Action
- Flamnability
- Explodability
- Storage Stability
- Viscosity
- Miscibility
- Corrosion Characteristics
MP
MP
MP
MP
MP
MP
MP
MP
MP
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
6 Months
6 Months
6 Months
6 Months
6 Months
15 Months
6 Months
6 Months
15 Months
Other Requirements:

64- 1 - Submittal of samples
MP
N/A
Yes
6 Months

-------
                                                           -140-
                                                       TABLE B
                PRODUCT SPECIFIC  DATA REQUIREMENTS  FOR MANUFACTURING-USE PRODUCTS CONTAINING CHEMICAL:
                                     O-ethyl O-p-nitrophenyl pheny]phosphonothioate     [EPN]
Data Requirenent
Composition
Does EE& Have
Data To Satisfy
This Require-
nent?  (Yes, No
or Partially)1
Bibliographic
  Citation *
 Wast Additional Data
 Be Submitted Under
 FIFRA § 3(c)(2)(B)?
Time Frane for Data
 Submission 2
§158.120 Product Chemistry (Continued)

  MP = Manufacturing-use Predict; R  = Required; CR = Conditionally Required

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

  2/ Data must be submitted within the  indicated time  frame, based on the date of the Guidance Document.
         6 Month Due Date is      OCTOBER 30, 1987    ;   12 Month Due Date is	APRIL 30, 1988	;
        15 Month Due Date is      JULY 30, 1988	.

-------
                                                          -141-
                                                      TABLE B
              PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANIFACTURING-USE PRODUCTS CONTAINING CHEMICAL:
                                   O-ethyl O-p-nitrqphenyl phenylphosphonothioate      [EPN]
Does EPA Have Mjst Additional Data
Data To Satisfy Be Submitted Under
I/ This Require- Bibliographic ETFRA § 3(c) (2) (B)?
Data Requirement Composition nent? (Yes/ No Citation Time Frame for Data
or Partially) Submission 3/
§158.135
Toxicology

ACUTE TESTING
81-1 -
81-2 -
81-3 -
81-4 -
81-5 -
81-6 -

Acute Oral Toxicity - Rat MP No
Acute Dermal Toxicity MP No
- Rabbit
Acute Inhalation Toxicity MP No
- Rat
Primary Eye MP No
Irritation - Rabbit
Primary Dermal MP No
Irritation - Rabbit
Denial Sensitization MP No
Guinea Pig
Yes 9 Months
Yes 9 Months
Yes 9 Months
Yes 9 Months
Yes 9 Months
Yes 9 Months

I/ Composition:  MP = Manufacturing-use product.

2/ Data must be submitted within the indicated time  frame, based  on the date of  the Guidance Document.
    0  9 Month Due Date is        JANUARY 30,  1988

-------
II.  LABELING APPENDICES

-------
                              -142-

                          SUMMARY-1

                        LABEL CONTENTS

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

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

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

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

     Item 4.  EPA REGISTRATION NUMBER - The registration
number assigned to the  pesticide product must  appear on the
label, preceded by the phrase "EPA Registration No.,"  or "EPA
Reg. No."  The registration number must be  set  in  type of  a
size and style similar  to other print on that part  of  the
label on which it appears and must run  parallel to  it.   The
registration number and the required identifying phrase  must
not appear in such a manner as to suggest  or imply  recommendation
or endorsement of the product by the Agency.
[40 CFR 162.lO(e)]

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

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

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                              -143-

                             SUMMARY-2

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

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

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

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

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

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

     Item 7C.  SKULL & CROSS BONES AND WORD "POISON" - On products
 assigned a toxicity Category I on  the basis of oral, dermal,
 or inhalation toxicity, the word "Poison" shall appear on the
 label in red on a background of distinctly contrasting color  and
 the skull and crossbones shall appear in  immediate proximity  to
 the word POISON.   [40 CFR 162.lO(h)(1)(i)]

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

     Item 7E.  REFERRAL STATEMENT - The statement "See Side
 (or Back) Panel for Additional Precautionary Statements"  is
 required on the front panel for all products, unless all
 required precautionary statements  appear on the front panel.
 [40 CFR 162.10(h) (1) (iii)]

     Item 8.  SIDE/BACK PANEL PRECAUTIONARY  IABELING - The
 precautionary statements listed below must appear together
 on the label under the heading  "PRECAUTIONARY STATEMENTS."
 The preferred location is at the top  of the side or back
 panel preceding the directions  for use, and it  is preferred
 that these statements be surrounded by a block outline.   Each
 of the three hazard warning statements must be headed by  the
 appropriate hazard title.   [40 CFR 162.lO(h)(2)].

-------
                              -144-

                          SUMMARY-3

    Item 8A.  HAZARD TO  HUMANS AND  DOMESTIC  ANIMALS - Where a
hazard exists to humans or domestic animals,  precautionary
statements are  required  indicating  the  particular hazard,  the
route(s) of exposure and the  precautions  to  be  taken to  avoid
accident, injury or damage.   [40 CFR  162.lO(h) (2) (i ) ]

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

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

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

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

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

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

-------
                             -145-

                          SUMMARY-4

     Classification Labeling Requirements

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

     1.  All uses restricted.

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

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

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

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

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

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

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

-------
                             -146-

                          SUMMARY-5

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

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

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

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

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                    -147-




                  SUMMARf-6






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

Above signal
word
Imnediately
below child
hazard
warninq
COMMENTS

If registrant is not the producer/ must
be qualified by "Packed for . . .,"
"Distributed by. . .," etc.
May be in metric units in addition to
U.S. units
Must be in similar type size and run
parallel to other type.
May appear on the container instead of
the label.
Text must run parallel with other text
on the panel.

All front panel precautionary statements
must be grouped together, preferably
blocked.
Note type size requirements.
Note type size requirements.

-------
  -148-




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

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



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

-------
  -149-




SLMMARY-8
ITEM
8C
9A
9B
1QA
10B
IOC
IABEL ELEMENT
Physical or
chemical
hazards
Restricted
block
Misuse
statement
Reentry
statement
Storage and
disposal block
Direct ions
for use
APPLE: ABC LIT*
OF REQUIREMENT
All pressurized
products, others
with flash
points under
150 °F
All restricted
products
All products
PR Notice 83-2
or as deteunined
by the Agency
All products
All predicts
PLACEMENT ON LABEL
REQUIRED
None
Top center
of front
panel
Itratedi ately
fo Hawing
heading of
directions
for use
In the
di rect ions
for use
In the
directions
for use
None
PREFERRED
Same as above
Preferably
blocked

Imnedi ately
after misuse
statement
Imnedi ately
before
specific
d'' rect ions
for use or
at the end of
di rect ions
for use
None
COMMENTS
Refer to Appendix II guide
PHYS/CHEM
Includes a statement of the terms of
restriction. The words "RESTRICTED USE
PESTICIDE" trust be sane type size as
signal word.
Required statement is:
"It is a violation of Federal law
to use this product in a manner
inconsistent with its labeling."

Mast be set apart and clearly distin-
guishable from from other directions
for use.
Refer to Appendix II guides STOR,
CONT/DIS, and PEST/DIS for further
information and required statements.
May be in ire trie as well as U.S. units

-------
                                         -150-
 PRCCAUnONARY STATEMENTS
   HAZARDS TO HUMANS
   ftDOMESTC ANMALS
     .  CAUTION
  ENVmONMENTAL HAZARDS
  PHYSICAL OH CHCMCAL
      HAZARDS
I h t tfoMo* tf Ndrt hi* to
M*  noduol h • mmr
   M-ENTOY STATEMENT
CROP:
   PRODUCT
        NAME
ACTVC MOREDENT:,
NERT MOREOCNT8:,

TOTAL
100.00%
                              THIS PRODUCT CONTAW3  LB8 OF  PER QAU.ON
                             KEEP OUT OF REACH OF CHILDREN
                                    CAUTION
                                  STATEMENT OF PRACTICAL TREATMENT
                          p SWALLOWED:
                          FMHALEOSSSS
                          PON8KNSSS
                          F M EYES =
                          SEE 8KXE PANEL FOA ADOfTlOMAL PRECAUTIONARY STATEMENTS
                          MFO BY     . 	
                          TOWN. STATE 7
                          ESTABLISHMENT NO. =
                          EPAREOISTRATlONNa:
                                     NET CONTENTS:
                                                                      CROP:;
                                                                      CROP;
                                                                      CROP:<
                                           STORAGE AND
                                             DISPOSAL
                                         STORAGE •,

                                         DISPOSAL;
                                                                         WARRANTY STATEMENT

-------
                                       -151-
PRECAUnONARY STATEMENTS

  HAZARDS TO HUMAN3

  (I OOMESTC ANMAL8)

      OANOER
 ENVIRONMENTAL HAZARD*
 PHYSICAL ON CHEMICAL

     HAZARDS
   DMEOTONS FOR USE

I * • '.HUM at Mdvri hv |»
      x •
  RE-ENTRY STATEMENT

    P Apple**)
  STORAGE AND

    DISPOSAL

 STOfUOE:
       RESTRICTED USE

           PESTICIDE    ,
       (reason for clasnifylnp)
       tKZ TO WO US CNLT 8T CBWiriB) AWUCMWS OR!
     ONTO 1H8IR DIMCT SOPCRVISION AND Wit FOR THOSE
USD ovtiaa) ir THE CERTIFIED APPUOOOR'S CERTIPICATION
        PRODUCT
            NAME
                            ACTIVE NOREDIENT: ,

                            MERT MQREOIENTS:,


                            TOTAU
                          100.00 X
                            THIS PRODUCT CONTAMS  IBS OF   PER GALLON
                           KEEP OUT OF REACH OF CHILDREN

                               DANGER —POISON
         STATEMENT OF PRACTCAL TREATMENT
  SWALLOWED:
                         r ON SKN

                         T N EYES
                         SEE 8OE PANEL FOR ADDITIONAL PRECAUTIONARY STATEMENTS
                         MFQBY—-

                         TOWN. STATE =====

                         ESTABLISHMENT NO.:
                         EPA REGISTRATION NO.;
                                   NET CONTENTS:
                                                                   CROP:
                                                                   CROP:
                                                                   CROP:
                                            CROP:.
                                            CROP:
                                                                      WARRANTY STATEMENT

-------
 § 162.8
                                 -152-
                                       40 CFR Ch. I (7-1-86 Edition)
  (fe) Conditional registration. Any a;
 plication for which aflreview of scie#-
 tifiddata is needed, otlher than an
 plication  which  the!  Agency   deter-
 mines may be  considered for uncondi-
 tional),  registration  under  parar  ~*~
 (d) of this section, will be treated
 application for condit
 under KIFRA  sec. 3(
 reviewea and acted
 in §§ 162A160 through
  (f) Denial of registration.
 ministrator shall  deify an ap;
 reviewed under p
 section if any  of th
 paragraph MX 2)  of
 not  met, or\if the:
 data to make\the
 tions.
  (1)  Notification.
 making a determina
 istration,  the \ A
                                  ph
                                  an
                      nal registration
                      (7) and vAll be
                      on as set/forth
                      62.177.
                              " e Ad-
                              lication
                              of this
                     requirements of
                     this  sefction are
                      are  Insufficient
                     uired/determina-
notif y the applk
of the denial of
set forth the ret
for the detei
tions, if any, whic
in order for the
proved.
  (2) Opportunity f^
cant (i) The appj
days from the
certified letter
corrective actioi
  (ii) The applk
Administrator tp witi
tion. The  A<
discretion, dez
drawal and pi
denial  in  accordant
(f )(3) of this/sectioi
  (3) FEDERAL REGIS
the applicant fails
ciency  of
the  Ad
issue in
of deni
shall set forth the
     for the denia
                     Prorfiptly  after
                    Jon to deny a reg-
                       ptrator  shall
                    )y Certified letter
                       Ition and shall
                      id factual basis
                      and  the condi-
                     lust be satisfied
                       ition to be ap-

                     remedy by appli-
                     it will have 30
                       receipt of the
                        the specified

                        petition the
                       LW his applica-
                    tion may, in his
                    petition for with-
                           a notice of
                     witti\  paragraph
         Unistratoi
        .e and addr< ss of the applicant.
        iuct name,
      ?e by weight <
basis
the
the
cen
dient in the produ
terns of use. and t!
cation.
  |f4) Hearing rigi
fallowing publica
  le FEDERAL REGI
  »y interested p
                   ation. If
           remedy the defi-
          ition application.
           shall  promptly
e FEDERA! REGISTER^ notice
of registration. Such notice
         •easons and factual
          and shall cpntain
         the name an6n the ebvironme;
that:
  (1) Hafe been ob
come to his atten
  (2) Insofar as
previously been
Agency.
Such informatio^  shall include, \but
shiul not be limited  to, published\or
  ipublished laboratory studies and
 fdent experience!
L48 FR 34005rJuly-26r49S33
                                                 ed by
                                               on; and
                                               e  is aware,
                                               submitted
                              or has

                                 not
                                 the
§ 162.10  Labeling requirements.
  (a)  General—(1)  Contents  of the
label Every pesticide products  shall
bear a label containing the informa-
tion specified by the Act and the  regu-
lations in this Part. The contents of a
label  must  show  clearly and  promi-
nently the following:
  (i) The name, brand,  or trademark
under which the product is sold as pre-
                                    122

-------
Environmental Protection Agency  -153-
                             $ 162.10
scribed  in  paragraph (b) of this sec-
tion:
  (ii)  The  name and  address  of the
producer,  registrant,  or person for
whom produced as prescribed in  para-
graph (c) of this section;
  ciii) The  net contents as  prescribed
in paragraph (d) of this section;
  (iv)   The   product   registration
number as  prescribed in paragraph (e)
of this section;
  (v)  The   producing  establishment
number as  prescribed in paragraph (f)
of this section;
  (vi) An ingredient  statement as pre-
scribed  in  paragraph (g) of this sec-
tion;
  (vii) Warning or precautionary state-
ments as prescribed  in paragraph (h)
of this section;
  (viii) The directions for use as pre-
scribed in paragraph (i) of this section;
and
  (ix) The  use classification(s) as pre-
scribed in paragraph (j) of this section.
  (2) Prominence and legibility, (i) All
words, statements, graphic representa-
tions, designs or other information re-
quired on the labeling  by the Act or
the regulations  in this part must be
clearly legible to a person with normal
vision, and must be  placed  with  such
conspicuousness  (as  compared  with
other words,  statements, designs, or
graphic matter  on  the labeling) and
expressed in such terms as to render it
likely to be read and understood by
the ordinary individual under custom-
ary conditions of purchase and use.
  (ii) All required label text must:
  (A)  Be set in 6-point or larger  type;
  (B)  Appear  on a  clear contrasting
background; and
  (C) Not be obscured or crowded.
  (3) Language to be  used. All required
label  or labeling text shall appear in
the English  language.  However, the
Agency  may require or the applicant
may propose additional text in other
languages as is considered necessary to
protect  the public.  When  additional
text in another language is necessary.
all labeling requirements will  be ap-
plied  equally to both the English and
other-language versions of  the label-
ing.
  (4) Placement of Label—(i) General.
The label shall appear on or be secure-
ly attached to the immediate contain-
er of the pesticide product. For  pur-
poses of  this  Section, and the  mis-
branding  provisions of the Act.  "se-
curely attached"  shall mean  that a
label can reasonably  bo  expected to
remain affixed during the foreseeable
conditions and period of use. If the im-
mediate container is enclosed within a
wrapper or outside container through
which the label cannot be clearly read.
the  label must also  be  securely at-
tached to such outside wrapper or  con-
tainer, if it is a part of the package as
customarily distributed or sold.
  (ii) Tank cars and  other bulk  con-
tainers—(A)  Transportation. While a
pesticide product is in transit,  the ap-
propriate  provisions of 49 CFR Parts
170-189, concerning the transportation
of hazardous materials, and specifical-
ly those provisions concerning the la-
beling, marking and placarding of  haz-
ardous materials and the  vehicles  car-
rying them,  define the basic Federal
requirements. In addition,  when  any
registered pesticide  product is trans-
ported in a  tank car, tank truck or
other mobile or portable bulk contain-
er, a copy of the accepted label must
be attached  to the shipping  papers,
and left with the consignee at the time
of delivery.
  (B) Storage.  When  pesticide prod-
ucts are  stored  in bulk containers,
whether  mobile or stationary,  which
remain in the  custody of the  user, a
copy of the label of labeling, including
all appropriate directions for use, shall
be securely attached to the container
in the immediate vicinity of the  dis-
charge control valve.
  (5) False or  misleading statements.
Pursuant  to  section 2(q)(l)(A) of the
Act, a pesticide or a  device declared
subject   to   the  Act pursuant  to
§ 162.15, is misbranded if its labeling is
false or misleading in any particular
including  both pesticidal and non-pes-
ticidal claims. Examples of statements
or  representations  in the labeling
which constitute misbranding include:
  (i) A false  or misleading statement
concerning  the composition   of  the
product;
  (ii) A false or misleading statement
concerning the effectiveness  of  the
product as a pesticide or device.
  (iii) A false or misleading statement
about the value of the  product for
                                    123

-------
 § 162.10
                               -154-
 purposes other than as a pesticide or
 device;
   (iv) A false or misleading comparison
 with other pesticides or devices;
   (v) Any statement directly or indi-
 rectly implying that the pesticide or
 device is recommended or endorsed by
 any  agency of the Federal  Govern-
 ment;
   (vi) The name of a  pesticide  which
 contains two or more  principal  active
 ingredients if the name suggests one
 or more  but not  all such  principal
 active ingredients  even  though  the
 names of the other  ingredients are
 stated elsewhere in the labeling;
   (vii) A true statement used in such a
 way as to give a false or misleading im-
 pression to the purchaser;
   (viii) Label disclaimers which negate
 or detract from labeling statements re-
 quired under the Act and these regula-
 tions;
   (ix) Claims as to the safety of the
 pesticide  or its  ingredients, including
 statements such as "safe." "nonpoison-
 ous," "noninjurious,"  "harmless"  or
 "nontoxic to humans  and pets" with
 or without such a qualifying phrase as
 "when used as directed"; and
  (x) Non-numerical and/or compara-
 tive statements  on the safety of the
 product, including but not limited to:
  (A) "Contains  all natural  ingredi-
 ents";
  (B) "Among the least toxic chemi-
 cals known"
  (C) "Pollution approved"
  (6) Final printed labeling, (i) Except
 as provided in paragraph faXGXii) of
 this  section,  final  printed   labeling
 must be submitted and accepted prior
 to registration. However, final printed
 labeling need not be submitted until
 draft label texts have  been provision-
 ally accepted by the Agency.
  (ii)  Clearly legible reproductions or
 photo reductions will be accepted for
 unusual  labels  such  as those  silk-
screened directly onto glass or  metal
containers or large bag or drum labels.
 Such reproductions must be of micro-
 film reproduction quality.
  (b)  Name, brand, or trademark. (1)
 The name, brand, or trademark under
 which the  pesticide product is sold
shall  appear on the front panel of the
 label.
         40 CFR Ch. I (7-1.86 Edition)

  (2) No name,  brand,  or trademark
 may appear on the label which:
  (i) Is false or misleading, or
  (ii) Has  not been approved  by the
 Administrator through registration or
 supplemental registration as an addi-
 tional name pursuant to § 162.6(b)(4).
  (c) Name and  address of producer,
 registrant,  or  person  for whom pro-
 duced. An  unqualified name and ad-
 dress given on the label shall be con-
 sidered as the name and address of the
 producer. If the  registrant's name ap-
 pears on the label and the registrant is
 not the producer, or if the name of the
 person for whom the  pesticide was
 produced appears on the label, it must
 be qualified by  appropriate wording
 such as "Packed for •  * *," "Distribut-
 ed by • * V or "Sold by * * •" to show
 that the name is not that of the pro-
 ducer.
  (d) Net weight  or measure of con-
 tents. (1) The net weight or measure
 of content shall be exclusive of wrap-
 pers or other materials and shall be
 the  average content unless explicitly
 stated as a minimum quantity.
  (2) If the pesticide  is a liquid, the
 net  content statement  shall  be  in
 terms of liquid measure at 68* F (20*C)
 and shall be expressed in conventional
 American units of fluid ounces,  pints,
 quarts, and gallons.
  (3) If the pesticide  is solid or semi-
 solid, viscous  or  pressurized, or is a
 mixture  of  liquid and solid, the net
 content statement shall be in terms of
 weight   expressed  as   avoirdupois
 pounds and ounces.
  (4) In all cases, net content shall be
stated in terms of the  largest suitable
 units, i.e.. "1 pound 10 ounces" rather
than "26 ounces."
  (5) In addition to the required units
specified, net  content  may be ex-
pressed in metric units.
  (6) Variation above  minimum  con-
tent  or around an average is permissi-
ble only  to the extent that it  repre-
sents deviation  unavoidable  in  good
manufacturing   practice.   Variation
 below a stated minimum, is not permit-
 ted.  In no case shall the average con-
 tent  of the packages in a shipment fall
below the stated average content.
  (e)  Product  registration  number.
The  registration  number assigned to
 the  pesticide product  at  the time of
                                   124

-------
Environmental Protection Agency
                                -155-
                            § 162.10
registration shall appear on the label.
preceded by the phrase "EPA Regis-
tration No.." or the phrase "EPA Reg.
No." The registration number shall be
set in type of a size and style similar to
other print on that part of the label
on which it appears and shall run par-
allel to it.  The  registration number
and the required identifying phrase
shall not appear in such a manner as
to suggest  or imply  recommendation
or endorsement of the product by  the
Agency.
  (f) Producing establishments  regis-
tration number. The  producing estab-
lishment registration number preced-
ed by  the phrase "EPA Est.", of  the
final establishment at which the prod-
uct was produced may appear in any
suitable location on the label or imme-
diate container. It must appear on  the
wrapper or outside  container of  the
package if the EPA establishment reg-
istration number on the  immediate
container   cannot  be  clearly  read
through such wrapper or container.
  (g) Ingredient statement—(1) Gener-
al The label of each pesticide product
must bear a statement which contains
the name and percentage by weight of
each active ingredient, the total per-
centage by  weight of  all inert ingredi-
ents; and if the pesticide contains ar-
senic in any form, a statement of  the
percentages of total and  water-soluble
arsenic calculated  as elemental  ar-
senic. The  active ingredients must be
designated by the term "active ingredi-
ents" and the inert ingredients by  the
term "inert ingredients," or the singu-
lar  forms of these terms when appro-
priate. Both terms shall  be in  the
same type size, be aligned to the same
margin and be equally prominent. The
statement "Inert Ingredients, none" is
not required for pesticides  which con-
tain 100 percent active ingredients.
Unless the  ingredient statement is a
complete analysis of the  pesticide,  the
term "analysis" shall not be used as a
heading for the ingredient statement.
  (2) Position of ingredient statement
(i)  The ingredient statement is nor-
mally required on the front panel of
the label. If there is an outside con-
tainer  or wrapper through which  the
ingredient statement cannot be clearly
read,  the Ingredient  statement must
also appear on such outside container
or wrapper. If the size or form of the
package  makes  it  impracticable  jto
place the ingredient statement on the
front panel of the  label,  permission
may  be  granted  for  the  ingredient
statement to appear elsewhere.
  (ii) The text of the ingredient state-
ment must run  parallel with other
text on the panel on which it appears.
and  must  be clearly  distinguishable
from and must not  be placed in the
body of other text.
  (3) Names to be used in ingredient
statement The name used for each in-
gredient   shall   be   the   accepted
common  name,  if there is one, fol-
lowed  by  the chemical name. The
common  name may be used-alone only
if it is well known. If no common name
has  been  established, the chemical
name alone shall be used.  In  no case
will the use of a trademark  or proprie-
tary name be permitted unless such
name has been accepted as a common
name by the Administrator under the
authority of section 25(c)(6).
  (4) Statements  of percentages. The
percentages of  ingredients shall  be
stated in terms  of  weight-to-weight.
The sum of percentages  of the active
and the inert ingredients shall be 100.
Percentages shall not be  expressed by
a range of values such as "22-25%." If
the uses of the  pesticide product are
expressed as weight of active  ingredi-
ent per unit area, a statement of the
weight of  active ingredient per unit
volume of the pesticide formulation
shall also  appear in  the  ingredient
statement.
  (5) Accuracy of stated percentages.
The percentages given shall be as pre-
cise as possible reflecting good manu-
facturing practice. If there may be un-
avoidable variation between manufac-
turing batches,  the value  stated for
each  active ingredient shall  be the
lowest  percentage  which  may  be
present.
  (6)  Deterioration.  Pesticides which
change in  chemical composition sig-
nificantly must meet the following la-
beling requirements:
  (i) In cases  where it is determined
that a pesticide formulation changes
chemical   composition   significantly.
the product must bear the following
statement in a prominent position on
                                   125

-------
 § 162.10
-156-
40 CFR Ch. I (7-1-86 Edition)
 the label: "Not  for sale or use after
 [date]."
  (ii) The product must meet all label
 claims up to the expiration time indi-
 cated on the label.
  (7) Inert  ingredients.  The Adminis-
 trator may require  the name of any
 inert ingredient(s) to be listed in the
 ingredient statement if he determines
 that such  ingredient(s)  may  pose a
 hazard to man or the environment.
  (h)  Warnings and  precautionary
 statements.   Required  warnings and
 precautionary statements concerning
 the  general  areas   of  toxicological
 hazard including hazard to children,
 environmental hazard, and physical or
        chemical hazard fall into two groups;
        those required on the front  panel of
        the  labeling  and those  which may
        appear  elsewhere.  Specific  require-
        ments concerning content, placement,
        type- size, and prominence are given
        below.
         (1) Required front panel statements.
        With  the  exception  of  the child
        hazard warning statement, the text re-
        quired on the front panel of the label
        is determined by the Toxicity Catego-
        ry of the pesticide. The category is as-
        signed on the  basis  of  the highest
        hazard shown by any of the indicators
        in the table below:

_
Hazard indicators
Oral LOM 	 ~.
Inhalation LC» 	
Dermal LDM 	
Eye effects 	
Skin effects 	



1
Up to and Jndudmg SO
mg/kg.
Up to and inckKfing 2.
ing/Her.
Up to and indudtog 200
mg/kg.
Corrosive' corneal
opacity not reversible
within 7 days.
Corrosive 	 	

Tmddtv c

II
From 50 thru 500 mg/kg..
From 2 thru 2 mg/fiter —
From 200 thru 2000 	
Comoal opacity
reversible within 7
J— , - f.-iH a 11 ii ii
oays; •iiiauoii
persisting for 7 days.
Severe irritation at 72
hours.


Ill
From €00 thru 5000 mg/
kg-
From 2. thru 20 mg/iter_
From 2.000 thru 20.000—
No corneal opacity"
Irritation reversible
within 7 days.
Moderate Irritation at 72
hours.


rv
Greater than 5000 mg/
kg.
Greater than 20 mg/ttter.
Greater than 20.000.
No irritation.
MMd or slight irritation at
72 hours.
  (i) Human hazard signal word—(A)
Toxicity Category I. All pesticide prod-
ucts meeting the criteria of Toxicity
Category I shall bear on the  front
panel the signal word "Danger." In ad-
dition if the product was assigned to
Toxicity Category I on the basis of its
oral, inhalation or dermal toxiclty (as
distinct  from skin  and eye  local ef-
fects) the word "Poison" shall appear
in red on a background of distinctly
contrasting  color and the skull and
crossbones shall appear in immediate
proximity to the word "poison."
  (B) Toxicity  Category II.  All  pesti-
cide products meeting the criteria of
Toxicity Category II shall bear on the
front panel the signal word "Warn-
ing."
  (C) Toxicity Category III. All  pesti-
cide products meeting the criteria of
Toxicity Category III shall  bear on
the front panel the signal word "Cau-
tion."
  (D) Toxicity  Category IV  All  pesti-
cide products meeting the criteria of
       Toxicity Category IV shall bear on the
       front panel the signal word "Caution."
         (E) Use of signal words. Use of any
       signal word(s) associated with a higher
       Toxicity Category  is not permitted
       except when the Agency determines
       that such labeling is necessary to pre-
       vent unreasonable adverse effects on
       man or the environment. In  no case
       shall more  than one human  hazard
       signal word appear on the front panel
       of a label.
         (ii) Child hazard warning. Every pes-
       ticide product label shall bear on the
       front panel the statement "keep out of
       reach  of children."  Only  in  cases
       where  the likelihood  of contact with
       children during distribution,  market-
       ing, storage or use is demonstrated by
       the applicant to be  extremely  remote,
       or if the nature of the pesticide is~5iich
       that it is approved for use on infants
       or small children, may the Administra-
       tor waive this requirement.
         (iii)  Statement of  practical  treat-
       ment—(A)  Toxicity  Category  I.  A
                                   126

-------
 Environmental Protection Agency
                                    -157-
                                                              § 162.10
statement of practical treatment (first
aid or other) shall appear on the front
panel of the label of all pesticides fall-
ing  into Toxicity Category  I on  the
basis of oral, inhalation or dermal tox-
icity.   The   Agency  may.  however.
permit  reasonable  variations in  the
placement of the statement  of practi-
cal treatment is some reference such
as "See statement  of practical treat-
ment  on back  panel" appears on  the
front  panel near the  word  "Poison"
and the skull and crossbones.
  (B)  Other toxicity categories.  The
statement of practical treatment is not
required on the front panel  except as
described in paragraph (h)QXiiiXA) of
this section. 'The' applicant may, how-
ever, include such a front panel state-
ment  at his  option.  Statements  of
practical treatment are, however, re-
quired  elsewhere   on  the  label  in
accord with paragraph  (h)(2) of this
section if they do not appear on  the
front panel.
  (iv)  Placement and prominence.  All
the require  front panel warning state-
ments  shall be grouped together on
the label, and shall  appear with suffi-
cient  prominence   relative   to other
front panel  text and graphic material
to make them unlikely to  be  over-
looked under customary conditions of
purchase and use. The following table
shows the minimum type size require-
ments  for   the  front panel  warning
statements on various sizes of labels:

Size of label front panel in square
inches
5 and unde» 	 	 	
Above 5 to 10 	
Above 10 to 15 	
Above 15 to 30 	
Over 30 	

Pa
Required
signal
word, all
capitals
6
10
12
14
18

nts
"Keep out
of reach of
children"
6
6
g
10
12

                                  (2) Other required warnings and pre-
                                cautionary statements. The warnings
                                and  precautionary statements as re-
                                quired below shall appear together on
                                the label  under the  general heading
                                "Precautionary    Statements"   and
                                under   appropriate   subheadings  of
                                "Hazard to Humans and Domestic Ani-
                                mals,"  "Environmental  Hazard" and
                                "Physical or Chemical Hazard."
                                  (i) Hazard to humans and domestic
                                animals. (A) Where a hazard exists to
                                humans or domestic  animals, precau-
                                tionary statements are required  indi-
                                cating  the  particular  hazard,   the
                                routeXs) of exposure  and the precau-
                                tions to be  taken to avoid accident.
                                injury or damage. The precautionary
                                paragraph shall be immediately pre-
                                ceded by the appropriate hazard signal
                                word.
                                  (B) The  following table depicts typi-
                                cal  precautionary statements. These
                                statements must be  modified or ex-
                                panded to reflect specific hazards.
  Toxicity
  category
                               Precautionary statements by toxicity category
                 Oral, inhalation, or dermal toxfctty
                                             Skin and eye local effects
III.
IV.
Fatal (poieonoue) if twaiowed [inhaled or absorbed
 through akin). Do not breathe vapor [duet or spray
 miet]. Do not get in eyes, on akin, or on dothing
 (Front panel statement of practical treatment re-
 quired.].
May be  fatal H swatowed [inhaled or  absorbed
 through the akin). Do not breathe vapors [duet or
 spray mist). Do not get in  eyes, on akin, or on
 dothing. (Appropriate first aid statements required.).
Harmful if swallowed [inhaled or ebeorbed through the
 skin). Avoid breathing vapors (duet or spray miet).
 Avoid contact with akin (eyes or dothing]. (Appro-
 priate first aid statement required.].
[No precautionary statements required.]		
Corrosive, causes eye and akin damage  (or skin
 irritation]. Do not get in eyes, on skin, or on
 dothing. Wear goggles or face shield and rubber
 gloves when handing. Harmful or fatal If swafewad.
 (Appropriate first aid statement required.]
Causes eye (and akin] irritation. Do not get in eyes.
 on skin, or on dothing. Harmful if swallowed. (Ap-
 propriate first aid statement required.]

Avoid contact with akin, eyes or dothing. In case of
 contact immediately flush eyes or skin with plenty of
 water. Get  medical .attention if irritation persists.

(No precautionary statements required.]
  (ii) Environmental hazards. Where a
hazard exists to non target organisms
excluding humans and domestic ani-
mals, precautionary statements are re-
                                quired  stating  the  nature  of  the
                                hazard  and the  appropriate  precau-
                                tions  to  avoid  potential  accident.
                                injury or  damage. Examples of  the
                                      127

-------
 § 162.10
-158-
40 CFR Ch. I (7-1-86 Edition)
 hazard statements  and  the  circum-
 stances under which they are required
 follow:
   (A) If a pesticide intended for out-
 door use contains an active ingredient
 with a mammalian acute oral LDM of
 100 or less, the statement "This Pesti-
 cide is Toxic to Wildlife" is required.
   (B) If a pesticide intended for out-
 door use contains an active ingredient
 with a fish acute LCM of 1 ppm or less,
 the statement "This Pesticide is Toxic
 to Pish" is required.
   (C)  If a pesticide intended for out-
 door use contains an  active ingredient
 with an avian acute  oral LDM  of  100
 mg/kg or less,  or a subacute dietary
 LCM of 500 ppm or less, the statement
 "This Pesticide is Toxic to Wildlife" is
 required.
   (D) If either accident history or field
 studies demonstrate  that use of the
         pesticide  may  result  in  fatality  to
         birds, fish or mammals, the statement
         "This pesticide is  extremely toxic to
         wildlife (fish)" is required.
           (E) For uses involving foliar applica-
         tion  to  agricultural crops, forests, or
         shade  trees,  or  for mosquito  abate-
         ment  treatments,  pesticides toxic  to
         pollinating insects must bear appropri-
         ate label cautions.
           (F) For all outdoor uses  other than
         aquatic  applications the  label  must
         bear  the caution "Keep out of lakes,
         ponds or streams. Do not contaminate
         water by cleaning of equipment or dis-
         posal of wastes."
           (ill)  Physical or  chemical hazards.
         Warning statements on the flammabil-
         ity or explosive characteristics of the
         pesticide are required as follows:
               Flashpoint
                      Required text
                               (A) PRESSURIZED CONTAINERS
Rash point at or below 20* F; if them to • flashback at
  any valve opening.
Flash point above 20* F and not over 80* F or If the
  flame extension is more than 16 in long at a Distance
  of 6 in from the flame.
AN other pressurized containers.......	
     Extremely flammable. Contents under pressure. Keep away from
      fire, sparks, and heated surfaces. Do not puncture or incinerate
      container. Exposure to temperatures above 130* F may cause
      bursting.
     Flammable. Contents under pressure.  Keep away  from  heat.
      sparks, and open flame. Do not puncture or Incinerate container.
      Exposure to temperatures above 130* F may cause bursting.
     Contents under pressure. Do not use or ston near heat or open
      flame. Do not puncture or incinerate container.  Exposure to
      temperatures above 130* F may cause bursting.
                             (B) NoNPRE&suRiZEO CONTAINERS
At or below 20* F.....
Above 20* F and not over 80* F_
Above 80* F and not over 150* F.
     Extremely flammable. Keep away from fire, sparks, and heated
      surfaces.
     Flammable. Keep away from heat and open flame.
     Do not use or store near heat or open flame.
  (i)  Directions for  Use—<1)  General
requirements—(I) Adequacy and clar-
ity of  directions. Directions  for use
must be stated in terms which can be
easily read and understood by the av-
erage person likely to use or to  super-
vise the use of the pesticide. When fol-
lowed, directions must be adequate to
protect  the  public  from  fraud  and
from personal  injury and to prevent
unreasonable  adverse  effects on the
environment.
  (ii) Placement of directions for use.
Directions may appear on any portion
of  the  label provided that they are
conspicuous enough  to be easily read
by  the  user of the  pesticide  product.
         Directions  for use may appear  on
         printed or  graphic matter which  ac-
         companies the pesticide provided that:
           (A) If required  by the Agency, such
         printed or graphic matter is securely
         attached to each  package of the pesti-
         cide,  or  placed  within  the  outside
         wrapper or bag;
           (B) The label bears a  reference to
         the directions for use in accompanying
         leaflets or circulars, such as "See  di-
         rections in the enclosed circular:" and
           (C) The  Administrator determines
         that it is not necessary for such direc-
         tions to appear on the label.
           (iii) Exceptions to requirement for
         direction  for use—(A) Detailed direc-
                                      128

-------
 Environmental Protection Agency   -159-
                            § 162.10
 t.ions for use may be omitted from la-
 beling of pesticides which are intended
 for use only by manufacturers of prod-
 ucts other than  pesticide products in
 their regular manufacturing processes,
 provided that:
  (1) The label clearly shows that the
 product  is intended for use only in
 manufacturing processes and specifies
 the type(s) of products involved.
  (2)  Adequate information  such as
 technical data sheets or bulletins,  is
 available to the  trade  specifying the
 type  of product  involved  and  its
 proper use in manufacturing process-
 es;
  (3) The product  will  not come into
 the hands of the  general public except
 after incorporation into finished prod-
 ucts; and
  (4)  The  Administrator determines
 that such directions are not necessary
 to prevent  unreasonable  adverse ef-
 fects on man or the environment.
  (B) Detailed  directions for use may
 be omitted from  the labeling of pesti-
 cide products for which sale is limited
 to physicians, veterinarians, or drug-
 gists, provided that:
  (1) The label clearly states that the
 product  is for use  only by physicians
 or veterinarians;
  (2)  The  Administrator determines
 that such directions are not necessary
 to prevent  unreasonable  adverse ef-
 fects on  man or the environment; and
  (3) The product  is also a drug and
 regulated under the provisions of the
 Federal Food. Drug and Cosmetic Act.
  (C) Detailed directions for use may
 be omitted from the labeling of pesti-
 cide products which are intended for
 use only by formulators in preparing
 pesticides for sale  to the public, pro-
 vided that:
  (1)  There  is  information readily
available to the  formulators on the
composition, toxicity, methods of use,
 applicable restrictions  or limitations,
 and  effectiveness of the product for
 pesticide purposes;
  (2) The label clearly states that the
 product  is intended  for use only in
 manufacturing,  formulating, mixing,
 or repacking for use as  a pesticide and
 specifies the type(s) of  pesticide prod-
 ucts involved;
  (3) The product as finally manufac-
tured,  formulated, mixed, or repack-
aged is registered; and
  (4)  The Administrator  determines
that such directions are not necessary
to prevent  unreasonable adverse  ef-
fects on man or the environment.
  (2) Contents of Directions for Use.
The directions for  use shall include
the following, under the headings "Di-
rections for Use':
  (i) The statement of use classifica-
tion as prescribed in 162.100) immedi-
ately  under  the heading "Directions
for Use."
  (ii)  Immediately  below  the  state-
ment of use classification, the  state-
ment "It is a violation of Federal law
to use this product in a manner incon-
sistent with its labeling."
  (iii) The site(s) of application,  as for
example the crops,  animals, areas,  or
objects to be  treated.
  (iv) The  target pestCs) associated
with each site.
  (v) The dosage rate associated with
each site and pest.
  (vl) The method of application,  in-
cluding instructions for dilution, if  re-
quired, and type(s) of application ap-
paratus or equipment required.
  (vii) The frequency and timing of ap-
plications necessary to obtain effective
results without  causing unreasonable
adverse effects on the environment.
  (viil) Specific limitations on reentry
to areas where the pesticide has been
applied,  meeting  the  requirements
concerning  reentry  provided  by  40
CFR Part 170.
  (ix) Specific directions  concerning
the storage and disposal of the pesti-
cide and its container, meeting the  re-
quirements of 40 CFR Part 165. These
instructions  shall  be  grouped and
appear  under the  heading "Storage
and Disposal." This heading must  be
set in type of the same minimum sizes
as required for the child hazard warn-
ing. (See Table in « 162.10
-------
 §162.11
-160-
40 CFR Ch. I (7-1-86 Edition)
   (C) Warnings as required against use
 on certain crops, animals, objects, or
 in or adjacent to certain areas.
   (D) [Reserved]
   (E) For restricted use pesticides, a
 statement that the  pesticide may be
 applied under the direct supervision of
 a certified applicator who is not phys-
 ically present at the site of application
 but  nonetheless  available   to  the
 person  applying the pesticide, unless
 the Agency has determined  that the
 pesticide may only be applied under
 the direct supervision of a certified ap-
 plicator who is physically present.
   (F)  Other  pertinent  information
 which  the Administrator  determines
 to be necessary for the protection of
 man and the environment.
   (J)  Statement of Use Classification.
 By October 22,1976, all pesticide prod-
 ucts must bear on their labels a state-
 ment of use classification as described
 in paragraphs (j) (1) and  (2) of this
 section.  Any  pesticide  product  for
 which some uses are classified for gen-
 eral use and others for restricted use
 shall be separately labeled according
 to the labeling standards set forth in
 this subsection, and shall be marketed
 as separate products with different
 registration numbers, one bearing di-
 rections only for general  useXs) and
 the  other bearing directions for re-
 stricted use(s) excep  that, if a product
 has both restricted use(s) and general
 use(s), both of these uses may appear
 on a product labeled for restricted use.
 Such products shall be subject to the
 orovisions of § 162.KXJX2).
  (1) General Use Classification. Pesti-
 cide products  bearing •directions  for
 use(s) classified general  shall  be la-
 beled with the exact words "General
 Classification" immediately below the
 heading "Directions for Use." And ref-
erence  to the  general classification
that suggests or implies that  the gen-
 eral utility of the  pesticide extends
beyond  those purposes and uses con-
tained in the Directions for Use will be
considered a false or misleading state-
ment under the statutory  definitions
of misbranding.
  (2)  Restricted  Use  Classification.
 Pesticide  products bearing direction
 for use(s)  classified restricted shall
 bear statements of restricted  use clas-
         sification  on the  front panel as  de-
         scribed below:
           (D Front panel statement of restrict-
         ed use classification. (A) At the top of
         the front panel of the label, set in type
         of the same minimum sizes as required
         for human hazard signal words (see
         table in § 162.10(h)(l)(iv)). and appear-
         ing with sufficient prominence relative
         to other text and graphic material on
         the front panel to make it unlikely to
         be overlooked under customary condi-
         tions of purchase  and use, the state-
         ment "Restricted Use Pesticide"  shall
         appear.
          (B) Directly below this statement on
         the front panel, a summary statement
         of the terms of restriction imposed as
         a  precondition to  registration  shall
         appear. If use is restricted to certified
         applicators, the following statement is
         required:  "For  retail sale to and use
         only by Certified Applicators or per-
         sons under their direct supervision and
         only for those uses covered by the Cer-
         tified  Applicator's  certification."  If,
         however, other  regulatory restrictions
         are  imposed,  the  Administrator will
         define the appropriate wording for the
         terms of restriction by regulation.
          (k) Advertising. [Reserved]

         [40 FR 28268. July 3. 1975;  40 FR 32329,
         Aug. 1, 1975; 40 FR 36571. Aug. 21. 1975. as
         amended at 43 FR 5786. Feb. 9.1978]
        § H2.ll
          (a)
        Criteria for
       mable adrc
       >) [Reserved]
         cl
              for
Except as provided
of this section, a
pesticide product n<
tered shall be
if each of the
forth in paragra]
(ill) of this sectio
the product use0)
for restricted
the labeling
(cX3) of thiXsection
product use may be
era!  use/or  the
strictecruse of the
the risks of
    icide. Each of th|
  'set forth below
  ic  product  use(s)
          ^terminations of
          I effect*,


           n—(1) ClcuMJica-
               reffistfations.
                   iph (cX4)
                       of a
           preously regis-
          edyfor general use
             le criteria set
           r(c)(l)(i) through
            met. Otherwise,
               be classified
                a review of
           ,t >to paragraph
                   that the
                   for gen-
           efits fr\hn~uhre-
             icide outweigh
           cted use  oil the
           separate criteria
          just be appliedXr
           to  be classifu
                                    130

-------
                              -161-
Criteria
       PHYS/CHEM-1

PHYSICAL/CHEMICAL HAZARDS

                  Required Label Statement
I.  Pressurized Containers

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

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

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

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

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

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

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

                  Flammable.  Keep away from
                  heat and open flame.

                  Do not use or store near
                  heat and open flame.

                  None reguired.

-------
                             -162-

                            STOR-1

             STORAGE INSTRUCTIONS FOR PESTICIDES

Heading;

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

Storage Instructions;

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

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

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

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

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

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

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

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                            -163-

                         PEST/DIS-1

             PESTICIDE DISPOSAL INSTRUCTIONS

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

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

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

    "Pesticide wastes are  acutely  hazardous.   Improper
    disposal of excess pesticide, spray mixture, or rinsate
    is a violation of Federal Law.   If these wastes  cannot be
    disposed of by use according to  label instructions,  contact
    your State Pesticide or Environmental Control  Agency,  or
    the Hazardous Waste representative at the nearest EPA
    Regional Office for guidance."

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

    "Pesticide wastes are  toxic.   Improper  disposal  of excess
     e   c de, spray mixture, or rinsate is a  violation  of


    Pesticide or Environmental Control Agency,  or  the
    Hazardous Waste representative at the nearest  EPA Regional
    Office for guidance."

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

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

5.  Products intended for  domestic use only must bear the
following disposal statement:

    "Securely wrap original container in several  layers
    of newspaper and discard in trash."

-------
                             -164-
                          CONT/DIS-1

               CONTAINER DISPOSAL INSTRUCTIONS

    The label of each product must  bear  container  disposal
instructions appropriate to the  type of  container.
    1.  Domestic use products must  bea:
container disposal statements:

Container Type
                                       one of  the  following
                                       Statement
Non-aerosol products
(bottlesr cansr jars)
Non-aerosol products
(bags )
Aerosol products
Do not reuse container (bottle, can, jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
    2.  All other products must
based on container  type, listed

 Container Type	
                               bear container
                               below:
                                              disposal instructions,
                                        Statement
 Metal
 containers
 (non-aerosol)
                       Triple rinse (or  equivalent).  Then  offer
                       for recycling or  reconditioning, or  puncture
                       and dispose of  in a  sanitary landfill, or  by
                       other procedures  approved  by state and  local
                       authorities.
 Plastic containers
                       Triple rinse  (or  equivalent).  Then  offer
                       for recycling or  reconditioning, or  puncture
                       and dispose of  in a  sanitary landfill, or
                       incineration, or,  if  allowed by  state  and
                       local authorities, by burning.   If burned,
                       stay out of smoke.
                         s^ay  out.  01  siuone.	
                         Triple  rinse (or equivalent).   Then dispose
                         of  in a sanitary  landfill or by other
                         approved  state  and  local  procedures.
Glass containers
 Fiber drums
 with liners
                       Completely empty liner  by  shaking  and
                       tapping sides  and  bottom to  loosen clinging
                       particles.  Empty  residue  into  application
                       equipment.  Then dispose of  liner  in a
                       sanitary landfill  or  by  incineration if
                       allowed by state and  local authorities.
                       If drum is contaminated  and  cannot be
                       reused^, dispose of in  the same manner*	
 Paper and
 plastic bags
                       Completely empty bag  into  application
                       equipment.  Then dispose of  empty  bag in
                       a sanitary landfill  or  by  incineration,
                       or,  if  allowed  by State and  local
                       authorities, by burning.   If  burned,  stay
                       out  of  smoke.
Compressed gas
cylinders
                         Return empty  cylinder
                         similar wording)
                                              for  reuse  (or
  \f Manufacturer may replace  this phrase  with  one  indicating
     whether  and how fiber drum  may  be reused.

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III.  USE INDEX APPENDIX

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                                    -165-
                     EPA Compendium of Acceptable Uses

             0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE*

                             TABLE OF CONTENTS

Site Name              	page

TERRESTRIAL FOOD CROP                                                2
  (Agricultural Crops)                                               2
  Almond                                                             3
  Apple                                                              4
  Apricot                                                            5
  Beans (including blackeyed peas, cowpeas, lima beans,  red
   kidney beans, and snap beans)                                     6
  Cherry                                                             5
  Citrus Fruits (including grapefruit, kumquat, lemon, lime,
   orange, tangelo, and tangerine)                                   8
  Corn (seed crop)                                                  10
  Corn, Field                                                        9
  Corn, Sweet                                                       11
  Cotton                                                            12
  Grapes                                                            15
  Nectarine                                                          5
  Olive                                                             15
  Peach                                                             16
  Pear                                                               4
  Pecan                                                             17
  Plum                                                               5
  Prune                                                              5
  Soybeans                                                          19
  Sugar Beets                                                       21
  Tomato                                                            21
  Walnut                                                            22

TERRESTRIAL NON-FOOD CROP                                           23
  (General Soil Treatment and Composting)                           23
  Earthworm Farms                                                   23
Issued:  8-15-85             III-041801-1
Provisional Update:   12-03-86

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                                              -166-
                               EPA Compendium of Acceptable Uses

'41801                  0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE*

          TYPE PESTICIDE;  Insecticide,  Acarlcide

          FORHULATIONS;
          Tech~(93%)
          FI   (80%).
          G    (0.26%, 1%, 2%, 4%)
          WP   (5%, 25%)
          EC   (2 Ib/gal, 3 Ib/gal, 4 Ib/gal, 5 Ib/gal)

          GENERAL WARNINGS AND LIMITATIONS;  All liquid femulations and any femu-
          lation greater than 4 percent are RESTRICTED USE PESTICIDES.  Do not use
          in combination with bordeaux or zinc sulfate-lime sprays.  Do not combine
          emulsifiable concentrate formulation with wettable powder formulation un-
          less previous use of this mixture has proven physically compatible and
          safe to plants.  Do not allow entry into treated fields within 24 hours
          after treatment, unless full protective clothing is worn.
          HANDLE THE CONCENTRATE ONLY WHEN WEARING THE FOLLOWING PROTECTIVE CLOTHING
          AND EQUIPMENT:  Wear a protective suit of 1 or 2 pieces that covers all
          parts of the body except the head, hands, and feet.  Wear chemical resis-
          tant gloves, chemical resistant apron, and chemical resistant shoes, shoe
          coverings, or boots.  Wear goggles or a face shield.  Wear a pesticide
          respirator approved by the National Institute for Occupational Safety and
          Heatlh under the provisions of 30 CFR Part II.  If handling the concen-
          trate with a closed system, a long sleeved shirt and long legged pants may
          be substituted for the protective suit and the respirator requirement is
          waived.
          WEAR THE FOLLOWING PROTECTIVE CLOTHING DURING APPLICATION, EQUIPMENT RE-
          PAIR, EQUIPMENT CLEANING, AND DURING EARLY REENTRY TO TREATED AREAS:  Wear
          a protective suit of 1 or 2 pieces that covers all parts of the body ex-
          cept the head, hands, and feet.  Wear chemical resistant gloves and chemi-
          cal resistant boots, shoes, or shoe coverings.  Application must be made
          only from a tractor with a completely enclosed cab or aerially with an
          enclosed cockpit.  For these applications a long sleeved shirt and long
          legged pants may be worn in place of the above protective clothing.  Chem-
          ical resistant gloves must be available in the cab or cockpit and must be
          worn while exiting.  This clothing is inadequate to protect you during
          equipment repair, cleaning or reentry.
          Refer to appropriate labeling for ENDANGERED SPECIES RESTRICTION^.
          Bee Caution;
          EPN is highly  toxic to bees exposed to direct treatment or residues on
          blooming crops or weeds.  Do not apply EPN or allow it to drift to bloom-
          ing crops or weeds if bees are visiting the treatment area.
          Agricultural Crop Tolerances;
          Beets (with or without tops)          3 ppm
          Beet greens                          3 ppm
          Blackberry                           3 ppm
          Boysenberry                          3 ppm
          Dewberry                             3 ppm
          Lettuce                              3 ppm
          Loganberry                           3 ppm
          Pineapple                            3 ppm

          *EPN

          Issued:  8-15-85             III-041801-1
          Provisional Update:  12-03-86

-------
                                    -167-

                     EPA Compendium of Acceptable Uses

              0-ETHYL  O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

GENERAL WARNINGS AND LIMITATIONS (continued)

Quince                               3 ppm
Raspberry                            3 ppm
Rutabaga (with or without tops)      3 ppm
Rutabaga (tops)                      3 ppm
Spinach                              3 ppm
Strawberry                           3 ppm
Turnips (with or without tops)       3 ppm
Turnips greens                       3 ppm
Youngberry                           3 ppm
Slte.and Pest           Dosages and   Tolerance, Use, Limitations
                        Formulatlon(s)

TERRESTRIAL FOOD CROP

  (Agricultural Crops)

  General Warnings and Limitations;  Do not use In home plantings nor ap-
  ply with hand equipment.  Do not use In mist blower type or thermal
  aerosol type (fog) equipment.  Consult your State Cooperative Agricul-
  tural Extension Service for proper timing of applications and for in-
  structions regarding posting treated areas.  When a dosage range is
  given, use the lower rate on small young plants or when Infestation is
  light.  Use the higher rate on large or mature plants or when infesta-
  tion is heavy.
  For fruits, apply the first cover spray following bloom or with the
  first sign of Infestation.  Repeat as needed unless otherwise specified.
  Granular formulations may be applied by aircraft.
  For wettable powder formulations, apply per acre rates in a minimum of
  20 gallons of water per acre by high pressure hydraulic equipment.
  For emulsifiable concentrate formulations, apply per acre rates in a
  minimum of 1 to 10 gallons of water by aircraft or in a minimum of 3 to
  10 gallons of water by low volume ground equipment.  Labeling^claims
  varying minimum gallonages depending on crop growth and size.  If low
  volume ground equipment is desired, the rate per 100 gallons should be
  adjusted in order to maintain the correct rate of active ingredient per
  acre.  For aerial applications, flagging must be by fully automated
  mechanical means or by humans working in totally enclosed vehicles.
  Emulsifiable concentrate formulations may be tank mixed with methyl
  parathion.
  Do not apply when weather conditions favor drift from areas treated.
Issued:  8-15-85             III-041801-2

-------
)3001AA
          Site and Pest
Almond
                      -168-

       EPA Compendium of  Acceptable Uses

0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

          Dosages and   Tolerance, Use, Limitations
          Formulation(s)

                         0.5  ppm
                         21 day preharvest  interval through
                         2 pounds  per  acre  for  foliar appli-
                         cation.
                         Do not apply  when  trees  or a sub-
                         stantial  number of weeds in the  or-
                         chard/grove are in bloom.
TAMABA
  Peach twig borer
LAVAM
  Spider mites  (in-
   cluding European
   red mite, Pacific
   spider mite  and
   twospotted spider
   mite)
           0.25 lb/
            100 gal
           (4, 5 Ib/gal
            EC)

           0.125-0.188
            lb/100 gal
            [max 800
            gal/A]
           (25% WP)
           (4, 5 Ib/gal
            EC)
Foliar application.
           Issued:  8-15-85
                            III-041801-3

-------
                                                -169-
            Site and Pest
  34001AA
  )4003AA
 TBUCSA
 NASAVA
 TBUAGA
 1RAXALA
CLAVAAA
/OA001AA
ITBUCSA
ITBUAGA

IRAXALA
INASAVA
                 EPA Compendium of Acceptable Uses

          0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

                    Dosages and   Tolerance, Use, Limitations
                    Formulation(s)

                                  3 ppm
                                  21 day preharvest interval (apples)
                                  or 14 day preharvest interval
                                  (pears) through 4.5 pounds per acre
                                  for foliar application.
                                  Do not apply when trees or a sub-
                                  stantial number of weeds in the or-
                                  chard/grove are in bloom.  Do not
                                  use on Mclntosh or related varieties
                                  (apples).
Codling moth
Plum curculio
Fruittree leaf-
 roller
Pear psylla
Spider mites (in-
 cluding European
 red mite, Pacific
 spider mite,
 Schoene spider
 mite, twospotted
 spider mite and
 Willamette spider
 mite)

  (Apple)
Codling moth
Fruittree leaf-
 roller
Pear psylla
Plum curculio
0.25-0.375
 lb/100 gal
(25% WP)
(4, 5 Ib/gal
 EC)
  or
1-1.5 Ib/A
(5 Ib/gal EC)

0.188-0.375
 lb/100 gal
(25% WP)
(4, 5 Ib/gal
 EC)

0.125-0.375
 lb/100 gal
(25% WP)
(4, 5 Ib/gal
 EC)

0.125-0.188
 lb/100 gal
(25% WP)
(4, 5 Ib/gal
 EC)
Foliar application.  Apply at petal
fall and repeat at 10 to 14 day in-
tervals as needed.
Foliar application.
0.5 lb/100    Foliar application.
 gal          May be formulated with methyl para-
 [900 gal/A]  thion.
(4 Ib/gal EC)
           Issued:  8-15-85
                         III-041801-4

-------
                                               -170-
                                EPA Compendium of Acceptable Uses

                        0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
 uAVAAA
05001AA
05002AA
05003AA
05005AA
05006AA
05004AA
           Site and Pest
Apple (continued)

  Spider mites (in-
   cluding European
   red mite, Pacific
   spider mite,
   Schoene spider
   mite, twospotted
   spider mite and
   Willamette spider
   mite)

Apr.lcot
Cherry
Nectarine
.RAHAVJG

:RAHAJG



ITBUAGA
   Cottony peach
    scale (crawlers)
   Lecanium scales
    (crawlers)
   Fruittree leaf-
    roller
LRAKBPG
   Olive scale
    (crawlers)
                      Dosages and   Tolerance, Use, Limitations
                      Formulation(s)
[MAI]
4.5 Ib/A
(3 Ib/gal EC)
0.313 lb/
 100 gal
(25% WP)
(4, 5 Ib/gal
 EC)

0.188 lb/
 100 gal
(25% WP)
(4, 5 Ib/gal
 EC)

0.625 lb/
 100 gal
(25% WP)
  or
0.25 lb/
 100 gal
  [plus  1.5%
 light  medium
 oil]
(25% WP)
3 ppm
21 day preharvest interval through
3 pounds per acre for foliar and
bark applications.
Delayed dormant application through
5 pounds per acre.  Do not make more
than 1 application during the delay-
ed dormant period.  Do not apply
when trees or a substantial number
of weeds in the orchard/grove are
in bloom.

Foliar application.
            Issued:   8-15-85
                            III-041801-5

-------
            Site  and  Pest
 LAVAAA
 :RAHAWG

 KAHAJG

 RAKBPG

 :TBUCJA
                                  -171-
                   EPA Compendium of Acceptable Uses

           0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

                      Dosages and   Tolerance, Use, Limitations
                      Formulation(s)
              Apricot;  cluster  (continued)
  Spider mites (in-
   cluding European
   red mite, Pacific
   spider mite, two-
   spotted spider
   mite and Willa-
   mette spider mite)

  Cottony peach
   scale (crawlers)
  Xecanium scales
   (crawlers)
  Olive scale
   (crawlers)
  Oriental fruit
   moth
                                    0.125-0.188
                                     lb/100 gal
                                    (25% WP)
                                    (4,  5 Ib/gal
                                     EC)
5 Ib/A        Delayed dormant application.   Apply
 [plus 1.5%   once at the time flower buds begin
 oil]         to swell.
(4, 5 Ib/gal
 EC)
 1TBQALA

 TBQAHA
CTBUCJA

CNASAVA
/28001AA
ITBCDCA
  Lesser peachtree
   borer
  Peachtree borer
  Oriental fruit
   moth
  Plum curculio
0.313-0.75    Bark application.  Make application
 lb/100 gal   during appearance of the moths  in
(25% WP)      early to late summer.  Apply 2  or  3
(4, 5 Ib/gal  sprays to trunk from ground to  scaf-
 EC)          fold limbs timed with moth flight.
  or
0.75-1.5 Ib/A
(5 Ib/gal EC)
0.25-0.375
 lb/100 gal
(25% WP)
(4, 5 Ib/gal
 EC)
  or
1-1.5 Ib/A
(5 Ib/gal EC)
Beans (including blackeyed peas,
 cowpeas, lima beans,  red kidney
 beans, and snap beansj
ITBMBWA
  Armyworm complex
   (Including beet
   armyworm and yel —
   lowstriped army-
   worm)
  Beet webworm
0.5-1 Ib/A
(2, 3, 4 lb/
 gal EC)
Foliar application.  Apply at petal
fall and repeat at 10 to 14 day  in-
tervals as needed.
3 ppm
21 day preharvest interval  through
1.5 pounds per acre for foliar  ap-
plication.
Do not feed treated vines to live-
stock.

Foliar application.
May be formulated with methyl para-
thlon.
            Issued:   8-15-85
                           III-041801-6

-------
 QAMACA
 OABADA

 QAMATA
 MOAAM
 TBCBOA

 TBMCCA
 KAPAFA
 LAVBEA
:RACAAA
TBCDCA
[NAMADA
CRAFAAA
[QAMARA
CLAAABA
CTBCCZA
INBUAAA
IQAQAAA
            Site and Pest
                                  -172-
                   EPA Compendium of  Acceptable Uses

            6-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

                       Dosages  and   Tolerance,  Use,  Limitations
                       Formulation(s)
'Beans  (continued)

   Pest list  continued  from previous page.

   Rapid plant  bug      [MAI]
   Serpentine leaf-    0.5-1 Ib/A
    miner complex      (2, 3 Ib/gal
   Tarnished plant  bug   EC)
   Thrips
   Tomato fruitworm
   European corn borer 0.25 Ib/A
                       (25% WP)
   Mexican bean beetle 0.125-1 Ib/A
   Twospotted spider
    mite
(25% WP)
(2,  4, 5 lb/
 gal EC)

[MAI]
0.125-1 Ib/A
(3 Ib/gal EC)
Foliar application.  Make 2 to 4
applications beginning 5 to 7 days
after eggs are laid.

Foliar application.  For Mexican
bean beetle, make 2 to 4 applica-
tions starting 5 to 7 days after
eggs are laid.
May be formulated with methyl para-
thion.
   Aphids
   Armyworm complex
    (including beet
    armyworm, southern
    armyworm, and yel-
    lows trlped army-
    worm)
   Flea beetles
   Leafhoppers
   Lygus bugs
   Mites (including
    russet mite)

   Climbing cutworms
   Darkling beetles
   Stink bugs
[MAI]         Foliar application.
0.25-1.5 Ib/A Formulated with methyl parathion.
(2, 3 Ib/gal
 EC)
[MAI]
0.67 Ib/A
(2 Ib/gal EC)

[MAI]
0.5-0.94 Ib/A
(3 Ib/gal EC)

[MAI]
0.5-1 Ib/A
(2, 3 Ib/gal
 EC)
            Issued:  8-15-85
                            III-041801-7

-------
 ZOOOAA
 AVARA
 IOCAOA
tOCAOA
CBUAGA

DBUALA
CAAAFA

IBUAGA

TBUALA
TAAAFA
           Site and Pest
             (Sherry
                                   -173-

                   EPA Compendium of Acceptable Uses

            0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

                      Dosages and   Tolerance, Use, Limitations
                      Formulation(s)
Citrus Fruits (including grape-
 fruit, kumquat, lemon,  lime,
 orange, tangelo, and tangerine)
  Citrus red mite
  Citrus thrips
Citrus thrips
Fruittree leaf
 roller
Orange tortrix
Orangeworms

Fruittree leaf-
 roller
Orange tortrix
  Orangeworms
0.25-0.375
 lb/100 gal
(25% WP)

0.5 lb/100
 gal
  or
2-3 Ib/A
(251 WP)
  or
0.5 Ib/A
(4, 5 Ib/gal
 EC)

1.5-2 Ib/A
(25% WP)
(4, 5 Ib/gal
 EC)
                                  See Apricot cluster.

                                  3 ppm
                                  30 day preharvest interval through
                                  8 pounds per acre for foliar appli-
                                  cation.
                                  Do not use treated rinds for food
                                  or feed.  Do not apply when trees
                                  or a substantial number of weeds in
                                  the orchard/grove are in bloom.

                                  Use limited to FL.
                                  Foliar application.
                                                 Foliar application.
                                  Foliar application.
                      4-8 Ib/A      Foliar application.
                      (4 Ib/gal  EC)
0.75-2.25
 Ib/A
(25% WP)
(4, 5 Ib/gal
 EC)

1.25-1.5 Ib/A
(25% WP)
(4, 5 Ib/gal
 EC)
           Issued:   8-15-85
                           III-041801-8

-------
 '8006AA
 TBCCFA
:TBCCZA
[NAMBHJ
IRACDKA
1QAQAAA
ITMBCCA
           Site and Pest
Corn, Field
  Armyworm
                               -174-
                EPA  Compendium  of  Acceptable  Uses

         0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

                   Dosages and   Tolerance, Use, Limitations
                   Formulation(s)

                                 3 ppm
                                 14 day preharvest interval through
                                 0.75  pound per acre for foliar ap-
                                 plication.
                                 Do not apply during the pollenshed
                                 period if bees are visiting  the
                                  treatment area.
                                 May be tank  mixed with methorny1.

                    0.47-0.5  Ib/A Foliar application.
                    (4,  5 Ib/gal May be formulated with methyl para-
                     EC)          thion.

                    [MAI]
                    0.25-0.5  Ib/A
                    (2,  3 Ib/gal
                     EC)
  Climbing cutworms
  Corn  rootworms
    (adults)
   Corn  leaf  aphids
   Stink .bugs
                    [MAI]
                    0.188-0.5
                     Ib/A
                    (2, 3 Ib/gal
                     EC)
Foliar application.
Formulated with methyl parathion.
                    0.23-0.5 Ib/A Foliar application.  Apply when
                    (4, 5 Ib/gal  pests first appear (to protect silk
                     EC)

                    [MAI]
                    0.188-0.25
                     Ib/A
                    (3 Ib/gal EC)

                    [MAI]
                    0.188-0.25
                     Ib/A
                    (3 Ib/gal EC)
                                                  from damage).
                                                  May be formulated with methyl para-
                                                  thion.
Foliar application.
Formulated with methyl parathion.
European corn borer 0.2-0.5 Ib/A  Foliar application.  Apply 10 days
                    (1Z, 2%, 4Z   after eggs first hatch or when 75
                     G)
                    (25Z WP)
                    (2, 3, 4, 5
                     Ib/gal EC)
                                      or
                                    0.75 Ib/A
                                     percent  of the  plants  show evidence
                                     of  feeding in leaf whorls.   Repeat
                                     7 to  10  days  later if  new evidence
                                     of  leaf  feeding is present.   For
                                     second brood, apply when eggs begin
                                     to  hatch.
                                    (4 Ib/gal EC) May be formulated with methyl para-
                                      or          thlon.
            Issued:  8-15-85
                            III-041801-9

-------
                                               -175-

                                 EPA Compendium of Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
            Site and Pest
                      Dosages  and   Tolerance,  Use,  Limitations
                      Formulation(s)
              Corn,  Field' (continued)
[TBCCOA
  Fall armyworm
CTBMAYA
  Southwestern corn
   borer
ILAVAAA
ITBCCXA
/28005BA
  Spider mites  (in-
   cluding Pacific
   spider mite  and
   twospotted
   spider mite)
  Surface feeding
   cutworms
Corn (seed crop)
INAMBHJ
ITMBCCA
  Corn rootworms
   (adults)
[MAI]
0.2-0.5 Ib/A
(2, 3 Ib/gal
 EC)

[MAI]
0.188-0.5
 Ib/A
(3 Ib/gal EC)
Foliar application.
Formulated with methyl parathion.
0.5 Ib/A      Foliar application.  For second to
(4, 5 Ib/gal  third generation borer, apply when
 EC)          10 percent of plant population have
              eggs masses.  Repeat at 5 to 10 day
[MAI]         intervals as needed.
0.25-0.5 Ib/A May be formulated with methyl para-
(3 Ib/gal EC) thion.

0.75 Ib/A     Foliar application.
(A Ib/gal EC) May be formulated with methyl para-
              thion.
[MAI]
0.5 Ib/A
(3 Ib/gal EC)
[MAI]
0.5 Ib/A
(2 Ib/gal EC)
Foliar application.
Formulated with methyl parathion.
              3 ppm
              14 day preharvest interval through
              0.5 pound per acre for foliar appli-
              cation (forage and fodder^.
              Do not apply during the pollenshed
              period if bees are visiting the
              treatment area.

0.25-0.5 Ib/A Foliar application to seed crop.
(4 Ib/gal EC) Apply when pests first appear (to
              protect silk from damage).
  European  corn  borer  0.2-0.5  Ib/A
                      (2,  4* G)
                      (25% WP)
                                                  Foliar application  to  seed  crop.
                                                  Apply when 25 percent  of  the  plants
                                                  show first brood whorl  feeding.
                                   (4 Ib/gal EC)  Repeat in 7 days if new feeding
                                                  damage occurs.  For second  brood,
                                                  apply at pollen shedding  and  while
                                                  plants are in the green silk  stage.
            Issued:  8-15-85
                          111-041801-10

-------
 L5005AA
TBCCFA
ITBCCZA
:NAMBHJ
ERACDKA
[QAQAAA
ITMBCCA
           Site and Pest
CoTn, Sweet
  Armyworm
                      -176-

       EPA Compendium of Acceptable Uses

0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

           Dosages and   Tolerance, Use,  Limitations
           Formulation(s)

                         3 ppm
                         14 day preharvest interval through
                         0.75 pound per acre for foliar ap-
                         plication.
                         Do not apply during the pollenshed
                         period if bees are visiting the
                         treatment area.
                         May be tank mixed with methorny1.

           0.47-0.5 Ib/A Foliar application.
           (4, 5 Ib/gal  May be formulated with methyl para-
            EC)          thion.

           [MAI]
           0.25-0.5 Ib/A
           (2, 3 Ib/gal
            EC)
  Climbing cutworms
  Corn rootworms
    (adults)
   Corn  leaf aphids
   Stink bugs
           [MAI]
           0.188-0.5
            Ib/A
           (2, 3 Ib/gal
            EC)
Foliar application.
Formulated with methyl parathion.
           0.23-0.5 Ib/A Foliar application.  Apply when
           (4, 5 Ib/gal  pests first appear (to protect silk
            EC)

           [MAI]
           0.188-0.25
            Ib/A
           (3 Ib/gal EC)

           [MAI]
           0.188-0.25
            Ib/A
           (3 Ib/gal EC)
                                                  from damage).
                                                  May be formulated with methyl para-
                                                  thion.
Foliar application.
Formulated with methyl parathion.
  European corn borer  0.2-0.5  Ib/A  Foliar application.   Apply when 25
                       (1%,  2Zt  4%   percent of the plants show evidence
                                     of leaf feeding.   Repeat  at 5  day
                                     intervals as  long as  leaf feeding
                                     is evident.   One  to 3 applications
                                     may be required.   For control  of
                                     second brood  borers,  apply when eggs
                                     begin to hatch.
                       (4  Ib/gal EC)  May be formulated with methyl  para-
                        or           thion.
                                     G)
                                    (25% WP)
                                    (2, 3, 4, 5
                                     Ib/gal EC)
                                      or
                                    0.75 Ib/A
            Issued:   8-15-85
                            III-0418 01-11

-------
                                               -177-

                                EPA Compendium of Acceptable Uses

                        0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
           Site and Pest
                      Dosages  and   Tolerance,  Use, Limitations
                      Formulation(s)
             Corn,  Sweet  (continued)
 BCOOA
  Fall armyworm
 BMAYA
  Southwestern corn
   borer
 AVAAA
TBCCXA
28007AA
  Spider mites  (in-
   cluding Pacific
   spider mite  and
   twospotted
   spider mite)
  Surface feeding
   cutworms
Cotton
RACAAA
  Aphids  (including
   cotton 'aphid)
[MAI]
0.2-0.5 Ib/A
(2, 3 lb/gal
 EC)

[MAI]
0.188-0.5
 Ib/A
(3 lb/gal EC)
Foliar application.
Formulated with methyl parathion.
0.5 Ib/A      Foliar application.  For second to
(4-5 lb/      third generation borer, apply when
 gal EC)      10 percent of plant population have
              eggs masses.  Repeat at 5 to 10 day
[MAI]         intervals as needed.
0.25-0.5 Ib/A May be formulated with methyl para-
(3 lb/gal EC) thion.

0.75 Ib/A     Foliar application.
(4 lb/gal EC) May be formulated with methyl para-
              thion .
[MAI]
0.5 Ib/A
(3 lb/gal EC)
[MAI]
0.5 Ib/A
(2 lb/gal EC)
Foliar application.
Formulated with methyl parathion.
[MAI]
0.125-0.67
 Ib/A
(2, 3 lb/gal
 EC)
0.5 ppm (cottonseed)
3 day preharvest or hand picking
interval through 1 pound per acre
for foliar application.
Do not feed treated forage or gin
trash to livestock.  Do not apply
to blooming cotton if bees are
visiting the treatment area.
May be tank mixed with chlordime-
form, chlordimeform hydrochloride
and methorny1.

Foliar application.
Formulated with methyl parathion.
           Issued:   8-15-85
                           111-041801-12

-------
TBCCNA
TABACA
TBCCSA
TAYAHA

TBCCQA
TBCAOA
QAMARA
INBUAAA
SAPAFA
10ABADA

1TBCCLA
:TBMBWA
ILAJAHA
XAVBEA
           Site and Pest
                                  -178-
                   EPA  Compendium of  Acceptable Uses

            0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

                      Dosages  and  Tolerance, Use, Limitations
                      Formulation(s)
"Corton  (continued)

  Beet  armyworm
  Saltmarsh  cater-
    pillar
   Cabbage looper
                    [MAI]
                    0.5-1 Ib/A
                    (2, 3 Ib/gal
                     EC)

                    [MAI]
Cotton leafperfer-  0.25-1 Ib/A
                    (2, 3 Ib/gal
                     EC)
    ator
   Yellow striped
    armyworm

   Cotton leaf worm
   Lygus bugs (and
    other mirids)
                     [MAI]
                     0.167-0.94
                     Ib/A
                     (2, 3 Ib/gal
                     EC)
   Darkling beetles     [MAI]
   Mexican bean beetle 0.94 Ib/A
   Serpentine leaf-    (3 Ib/gal EC)
    miner
   Southern armyworm
   Sugarbeet webworm
   Tomato russet mite
   Twospotted spider
    mite
ITBCCOA
DLAVAAA
[QAMBDA
ITBMBVA
IVABAAA
IKOAAAA
   Fall armyworm
   Spider mites
   Fleahoppers (in-
    cluding cotton
    fleahopper)
   Garden webworm
   Grasshoppers
   Thrips
                     [MAI]
                     0.125-0.56
                     Ib/A
                     (2, 3 Ib/gal
                     EC)

                     [MAI]
                     0.0635-0.94
                     Ib/A
                     (2, 3 Ib/gal
                     EC)
                          -0.67
                      Ib/A
                     (2,  3 Ib/gal
                      EC)
            Issued:   8-15-85
                             111-041801-13

-------
                                                -179-

                                 EPA  Compendium  of  Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
 JAMACA
 JAMATA
 IBCCNA
 QAMACA
 DABADA

 IBCCLA
 QAMATA

 HAS AHA
:TBCBOA
ITAMADA
:TBCBNA
IRAFCFA
ITBCADA
ILAVAAA
DtOAAAA
ITBCCQA
            Site  and  Pest
              Cotton (continued)
                    Dosages and   Tolerance, Use, Limitations
                    Fortnulation( s)
Rapid plant bug     [MAI]
Tarnished plant bug 0.67-0.94
                     Ib/A
                    (2, 3 Ib/gal
                     EC)
Beet armyworm
Rapid plant bug
Serpentine leaf-
 miner complex
Southern armyworm
Tarnished plant bug

Boll weevil
1 Ib/A        Foliar application.
(4 Ib/gal EC)
Bollworm
Pink bollworm
Tobacco budworm
Cotton fleahoppers
Cotton leafworm
Spider mites
Thrips
Yellowstriped
 armyworm
0.5-1 Ib/A
(2, 4, 5 lb/
 gal EC)
              Foliar application.  Apply when
              plants are fruiting and 10 to 25
              percent of squares are punctured.
              Repeat at 5 day intervals as needed.
                                    0.188-0.94     Foliar application.   Apply the lower
                                    Ib/A          dosage for overwintered adults.
                                    (5 Ib/gal EC)  Apply the higher dosage for middle
                                                  and late season control.
                                    [MAI]          May be formulated with methyl para-
                                    0.1-0.67 Ib/A  thion.
                                    (2,  3  Ib/gal
                                    EC)
0.94-1 Ib/A
(2, 4, 5 lb/
 gal EC)

[MAI]
0.33-1 Ib/A
(2, 3 Ib/gal
 EC)
              Foliar application.  For bollworm,
              apply when eggs and 4 to 5 larvae
              per 100 terminals are found or be-
              fore larvae have infested bolls.
              May be formulated with methyl para-
              thion.
0.313-0.625   Foliar application.  Apply when
 Ib/A         pests first appear and repeat at 4
(2, 4, 5 lb/  to 5 day intervals as needed.
 gal EC)
            Issued:   8-15-85
                         111-041801-14

-------
                                               -180-
 1014AA
 :BGBDA
IAFAOA
LAVAAA
28014AA
IRAHAWG

CRAHAJG
           Site and Pest
Grapes
       EPA  Compendium  of  Acceptable Uses

0-ETHYL O-(p-KITROPHENYL) PHENYLPHOSPHONOTHIOATE

          Dosages  and   Tolerance, Use, Limitations
          Formulation(s)

                        3 ppm
                        21 day  preharvest interval through
                        0.75 pound per acre  for  foliar
                        application.
  Grape berry moth
                                    Foliar application.
  Grape leafhopper
           0.25 Ib/A
           (25% WP)
             or
           0.25 lb/100
            gal
           (25% WP)
           (4, 5 Ib/gal
            EC)
             or
           0.75 Ib/A
           (4 Ib/gal EC)
           [MAIJ         Foliar application.
           0.75 Ib/A     Formulated with methyl parathion.
           (3 Ib/gal EC)
                       0.125-0.188
                        lb/100 gal
                       (25% WP)
  Spider mites (In-
   cluding European
   red mite, Pacific
   spider mite, two-  (4, 5 Ib/gal
   spotted spider      EC)
   mite and Willa-
   mette spider       [MAI]
   mite)              0.75 Ib/A
                      (3 Ib/gal EC)

Nectarine

Olive
                         Foliar application.
                         May be formulated with methyl para-
                         thion.
                                     See Apricot cluster.

                                     3 ppm
                                     Foliar application  through^!2
                                     pounds per acre.
                                     Do not apply after  July  15.
   Cottony peach scale  0.313 lb/     Foliar application.
    (crawlers)
  Lecanium scales
    (crawlers)
            100 gal
            [max 4 Ib/A]
            (25% WP)
             or
            4-6 Ib/A
            (4 Ib/gal EC)
             or
            8-12 Ib/A
            (4, 5 Ib/gal
            EC)
            Issued:   8-15-85
                            111-041801-15

-------
                                                -181-

                                EPA Compendium of Acceptable Uses

                        0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
 AKBPG
           Site and Pest
Olive (continued)

  Olive scale
   (crawlers)
                      Dosages and   Tolerance, Use^ Limitations
                      Formulation(s)
0.625 lb/
 100 gal
 [max 4 Ib/A]
(25% WP)
  or
0.25 lb/
 100 gal
 [plus 1.5%
 light medium
 oil]
(25% WP)
  or
4-6 Ib/A
(4 Ib/gal EC)
  or
8-12 Ib/A
(4, 5 Ib/gal
 EC)
 )5004AA
Peach
NASAVA
QAMATA
  Plum curculio       [MAI]
  Tarnished plant bug 0.375 lb/100
                       gal
                      (5% WP)
RAHAWG

RAHAJC

:TBUCJA
:NASAVA
:QAMATA
  Cottony peach
   scale (crawlers)
  Lecanium scale
   (crawlers)
  Oriental fruit moth
  Plum curculio
  Tarnished plant bug-
[MAI]
0.375 lb/100
 gal
(5% WP)
3 ppm
21 day preharvest interval through
3 pounds per acre for foliar and
bark applications.
Delayed dormant application through
5 pounds per acre.  Do not make more
than 1 application during the delay-
ed dormant period.  Do not apply
when trees or a substantial number
of weeds in the orchard/grove are
in bloom.

Delayed dormant and foliar applica-
tion.  Apply in the first 2_or  3
early season sprays.  For the con-
trol of overwintering generation of
the plum curculio.
Formulated with sulfur.

Foliar application.  May be applied
in a complete spray schedule.   Early
ripening varieties will not require
the full schedule of application.
Formulated with sulfur.
             Pear

           Issued:  8-15-85
                      Also refer to Apricot cluster for additional pest
                      and use information.

                                    See  Apple cluster.

                           111-041801-16

-------
                                               -182-
03008AA
           Site and Pest
Pecan
        EPA Compendium of  Acceptable  Uses

0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

           Dosages  and  Tolerance, Use, Limitations
           Formulation( s)'

                        0.5  ppm
                         21 day preharvest  interval through
                        3.75 pounds  per acre  for  foliar ap-
                        plication.
                        Do not graze livestock in treated
                        groves.   Do  not use in home  plant-
                         ings.
RACAAA
LAAABA
  Aphids
  Mites (excluding
   spider mites)
[TABAIA
:TBDABA
  Fall webworm
  Walnut caterpillar
CTBGAXA
[NASBBA
  Hickory shuckworm
  Pecan weevil
           0.3-0.5 lb/   Foliar application.  Apply when
            100 gal      pests first appear or when injury
           (25% WP)      is first seen.   Repeat as needed.
           (2, 4, 5 lb/  May be formulated with parathion.
            gal EC)
             or
           1-1.5 Ib/A
           (4 Ib/gal EC)

           [MAI]
           2 Ib/A
           (4 Ib/gal EC)

           0.375-0.5 lb/ Foliar application.  Apply while
            100 gal      caterpillars are small.
           (25% WP)      Kay be formulated with parathion.
           (2, 4, 5 lb/
            gal EC)

           [MAI]
           2 Ib/A
           (4 Ib/gal EC)
           0.5 lb/100
            gal
           (25% WP)
             or
           0.375-0.5
            lb/100 gal
            [250-500
            gal/A]
             or
           1.25-2.5 Ib/A
           (2, 4, 5 lb/
            gal EC)

           [MAI]
           2 Ib/A
           (4 Ib/gal EC)
Foliar application.  For hickory
shuckworm, make first application
at time of shell hardening or about
August 10 to 15.  Make.,2 additional
applications at 14 day intervals.
This treatment will also control the
pecan weevil.  If pecan weevil is
the only pest, make only 2 applica-
tions.  Make first application about
August 1 to 10 or when 6 or more
weevils can be jarred from a single
tree.  Repeat 10 to 14 days later.
May be formulated with parathion.
            Issued:   8-15-85
                           111-041801-17

-------
 fBPAEA
 rBMAFA
 TBMADA
 QAQALA
CLAVAAA
                                               -183-
                                EPA Compendium of Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE
Site and Pest


  "Pecan (continued)

    May beetles
    Pecan leaf case-
     bearer
    Pecan nut case-
     bearer
    Southern green
     stink bug
                                   Dosages and   Tolerance, Use, Limitations
                                   Fonnulation(s)
0.375-0.5 lb/ Foliar application.  Apply when
 100 gal      beetles appear in the spring.
(25% WP)
(2, 4, 5 lb/
 gal EC)
              Foliar application.  Apply when
              pest first appears and repeat as
              needed.
              May be formulated with parathion.
0.4-0.5 lb/
 100 gal
 [250-300
 gal/A]
(25% WP)
(2, 4, 5 lb/
 gal EC)
  or
1.25-1.56
 Ib/A
(5 Ib/gal EC)

[MAI]
2 Ib/A
(4 Ib/gal EC)
0.3-0.5 lb/   Foliar application.  Apply when tips
 100 gal      of small nuts begin to turn brown.
(25% WP)      Repeat at 7 to 10 day intervals as
(2, 4, 5 lb/  needed.
 gal EC)      May be formulated with parathion.
  or
1-3.5 Ib/A
(4, 5 Ib/gal
 EC)

[MAI]
2 Ib/A
(4 Ib/gal EC)

0.375-0.5 lb/ Foliar application.
 100 gal
(25% WP)
(2, 4, 5 lb/
 gal EC)
    Spider mites  (in-   0.125-0.188   Foliar  application.
     eluding twospotted   lb/100 gal   May be  formulated with  parathion.
                        (25%  WP)
                        (4, 5 Ib/gal
                         EC)
                spider mite)
                                     or
           Issued:  8-15-85
                             111-041801-18

-------
 RAEAAA
 NALBCA
'28023AA
CRACAAA
ITBCCFA
INAMARA
INBGAAA
                                               -184-

                                EPA Compendium of Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
           Site and Pest
             "Pecan (continued)
  Spittlebugs
  Twig girdler
Plum

Prune

Soybeans




  Aphids
  Armyworm
  Bean leaf beetle
  Blister beetles
                     Dosages and   Tolerance,  Use,  Limitations
                     Formulation(s)
3-3.5 Ib/A
(4 Ib/gal EC)

[MAI]
2 Ib/A
(4 Ib/gal EC)

[MAI]         Foliar application.  Apply when
2 Ib/A        pest appears.  If past experience
(4 Ib/gal EC) indicates spittlebugs will be a
              problem, apply to the second pre-
              pollination spray.
              Formulated with parathion.

0.375-0.5 lb/ Foliar application.  Make 3 appli-
 100 gal      cations at 14 day intervals begin-
(25% WP)      ning when damage appears.
(2, 4, 5 lb/ May be formulated with methyl para-
 gal EC)      thion.

[MAI]
2 Ib/A
(4 Ib/gal EC)

              See Apricot cluster.

              See Apricot cluster.

              0.05 ppm (negligible residue)
              21 day preharvest, prefeeding and
              pregrazing interval through 1 pound
              per acre for foliar application.
 [MAI]
 0.25-0.52
 Ib/A
 (2, 3 Ib/gal
 EC)

 [MAI]
 0.5 Ib/A
 (2 Ib/gal  EC)

 [MAI]
 0.25-0.375
 Ib/A
 (2, 3 Ib/gal
 EC)
Foliar application.
Formulated with methyl parathion.
            Issued:   8-15-85
                           111-041801-19

-------
 TBCCSA
 TBCCCA
CTBCCZA
CRASADA

LTAAAMA
CTBCCOC
CTABACA
LNAPAFA
IQAQAAA
ILAVBEA

ITBCATA



ITBCBOA
                                               -185-
                                 EPA Compendium of Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE
            Site  and  Pest
Soybeans (continued)

  Cabbage looper
  Green cloverworm
  Climbing cutworms
  Threecornered
   alfalfa looper
  Webworms (includ-
   ing garden web-
   worm)

  Fall armyworm (up
   to 3rd instar
   larvae)
  Saltmarsh cater-
   pillar
                      Dosages and   Tolerance, Use, Limitations
                      Formulation^s)
[MAI]
0.25-0.75
 Ib/A
(2, 3 Ib/gal
 EC)

[MAI]
0.125-0.52
 Ib/A
(2, 3 Ib/gal
 EC)
[MAI]
0.5-1 Ib/A
(2, 3 Ib/gal
 EC)
  Mexican bean beetle [MAI]
                      0.25-1 Ib/A
                      (2, 3 Ib/gal
                       EC)
  Stink bugs
  Twospotted spider
   mite
  Velvetbean cater-
   pillar
  Corn earworm
[MAI]
0.63-1 Ib/A
(2, 3 Ib/gal
 EC)

[MAI]
0.2-0.375
 Ib/A
(2, 3 Ib/gal
 EC)

1 Ib/A        Foliar application.  Apply when
(A, 5 Ib/gal  larval counts show 1 larva per 3
 EC)          feet of row.  Repeat as needed.
              May be formulated with methyl para-
[MAI]         thion.
0.375-1 Ib/A
(2, 3 Ib/gal
 EC)
            Issued:   8-15-85
                           III-OA1801-20

-------
 2802OAA
1TBCCNA
[TBMBWA
1QAMACA
[OABADA

[QAMATA
EMOAAAA
ILAVBEA
/11005AA
IRACAAA
ITBCDCA
ITBCCSA
INAMADA
IRAFAAA
IMAAAGA
IRACCHA
IRAXAAA
IQAMACA
IQAMATA
IMOAAAA
HBCBOA
ITBRAJA
ITBMANA
ILAJAHA
ILAVBEA
           Site and Pest
Sugar Beets'
                     -186-
       EPA Compendium  of Acceptable Uses

0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

           Dosages and    Tolerance, Use, Limitations
           Formulatlon(s)

                         3 ppm (roots)
                         21 day preharvest interval through
                         1 pound per acre for foliar appli-
                         cation.
  Beet armyworm
  Beet webworm
  Rapid plant bug
  Serpentine leaf-
   miner complex
  Tarnished plant bug
  Thrips
  Twospotted spider
   mite

Tomato
           1 Ib/A
           (4,  5 Ib/gal
            EC)
Foliar application,
  Aphids
  Armyworm complex
   (including beet
   armyworm, southern
   armyworm> and
   yellowstriped
   armyworm)
  Cabbage looper
  Flea beetle
  Leafhoppers
  Leafminers (includ-
   ing serpentine
   leafminer complex)
  Potato aphid
  Psyllids
  Rapid plant bug
  Tarnished plant bug
  Thrips
  Tomato fruitworm
  Tomato hornworm
  Tomato pinworm
  Tomato russet mite
  Twospotted spider
   mite
           0.125-0.25
            Ib/A
           (25% WP)
             or
           0.25-1 Ib/A
           (2, 3, 4, 5
            Ib/gal EC)

           [MAI]
           0.125-0.25
            Ib/A
           (2, 3 Ib/gal
            EC)
3 ppm
3 day preharvest interval through
0.25 pound per acre for foliar ap-
plication.
21 day preharvest interval from
above 0.25 through 1 pound per acre
for foliar application.

Foliar application.  Repeat at 7 to
10 day intervals as needed.
May be formulated with methyl para-
thion.
            Issued:  8-15-85
                            III-041801-21

-------
 D3009AA
           Site and Pest
"Walnut
                      -187-
       EPA  Compendium of  Acceptable  Uses

0-ETHYL O-(p-NITROPHENYL) PHENYLPROSPHONOTHIGATE

          Dosages and  Tolerance, Use,  Limitatlons
          Formulation(s)

                        0.5 ppm
                        21 day preharvest  interval through
                        2 pounds per acre  of wettable  powder
                        formulation or 3.5 pounds per  acre
                        of emulslfiable  concentrate  formu-
                        lations for foliar application.   Do
                        not graze livestock in treated
                        groves.
TBUCSA
RACBHA
   Codling moth
   Walnut aphid
TBUAGA
   Fruittree leaf-
    roller
LAVAAA
  Spider mites (in-
   cluding European
   red mite, Pacific
   spider mite and
   twospotted spider
   mite)
          0.25 lb/      Foliar application.  For codling
           100 gal      moth, apply at petal fall and repeat
          (25% WP)      at 10 to 14 day intervals as needed.
          (4, 5 Ib/gal
           EC)
            or
          3-3.5 Ib/A
          (4 Ib/gal EC)
          0.188 lb/100
           gal
          (25% WP)
          (4, 5 Ib/gal
           EC)
            or
          3-3.5 Ib/A
          (4 Ib/gal EC)

          0.125-0.188
           lb/100 gal
          (25% WP)
          (4, 5 Ib/gal
           EC)
            or
          3-3.5 Ib/A
          (4 Ib/gal EC)
Foliar application.
           Issued:   8-15-85
                           111-041801-22

-------
           Site and Pest
                                 -188-

                  EPA Compendium of Acceptable Uses

           0-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

                     Dosages and   Tolerance, Use, Limitations
                     Formulation(s)
           TERRESTRIAL NON-FOOD CROP

             (General Soil Treatment and Composting)

610170A      Earthworm Farms
                                                 30 day preharvest interval through
                                                 0.0416 ounce per 100 square feet for
                                                 earthworm soil treatment.
                                                 Do not make more than 2 applications
                                                 per year.  Wear protective rubber
                                                 gloves during treatment and worm
                                                 harvest.  If earthworm pits are
                                                 located indoors such as a utility
                                                 building or barn, make sure to va-
                                                 cate the area of pets, fish, and
                                                 wildlife.  After treatment, close
                                                 doors and leave closed for a 24
                                                 hour period.  Thoroughly ventilate
                                                 before reentry.

LBHABA         Red fishworm mite   0.0416 oz/100 Earthworm soil treatment.  Apply to
                                    sq.ft        earthworm enclosed soil pits.  Dis-
                                   (0.26% G)     tribute the granules evenly over the
                                                 soil surface and follow with a light
                                                 watering to move the granules into
                                                 the soil surface.  Red fishworm mite
                                                 will be controlled for up to 30 to
                                                 40 days.  Repeat if needed.  If the
                                                 soil has become heavily infested
                                                 after treatments remove the soil and
                                                 replace with new soil.
            AERIAL, MOTHPROOFING AND TANK MIX APPLICATIONS
>001500
lAAAAAA
Aerial Application
5900300
AAAAAAA
Tank Mix
                                   Refer  to
                                   TERRESTRIAL  FOOD  CROP
                                     (Agricultural  dropsy
                                                 All sites
                                   Refer  to
                                   TERRESTRIAL  FOOD  CROP
                                     (Agricultural  Crops)
                                                 All sites
            Issued:   8-15-85
                           111-041801-23

-------
                                              -189-

                                 EPA Compendium of Acceptable Uses

                         O-ETHYL O-(p-NITROPHENYL) PHENYLPHOSPHONOTHIOATE

            Listing of Registered Pesticide Products by Formulation

&293.0001   33Vtechnical chemical
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                003442-00681***007001-00348***
                  ***voluntary cancellation

&280.0002   80% formulation intermediate
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                000352-00338***

              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801) plus xylene
               range aromatic solvent (086803)
                000876-00235***009566-00002***
                  ***voluntary cancellation

&000.2604   0.26% granular
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                047056-00003

&001.0004   1% granular
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                019713-00120

&002.0004   2% granular
              O-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                000876-00408   002393-00219   005905-00171   044215-00013

&004.0004   4% granular
              O-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                000876-00407   002393-00232   005905-00181   008590-00625
                034704-00059   044215-00021

&005.0006   5% wettable powder
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801) plus sulfur or
               sulphur (077501)
                000769-00382

&025.0006   25% wettable powder
              O-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801)
                000279-02675** 000769-00276   000876-00438   001842-00267
                002169-00186*
                  *jacket currently unavailable for review
                  **suspended

&102.0012   2 Ib/gal emulsifiable concentrate
              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801) plus aromatic
               petroleum derivative solvent (006501)
                005905-00101

              0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (0*1801) plus xylene
               (086802)
                005905-00134
            Issued:  8-15-85
111-041801-24

-------
                                              -190-

                               EPA Compendium of Acceptable Uses

                       •0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

          Listing of Registered Pesticide Products by Formulation  (continued)

          2 Ib/gal emuls.iflable concentrate  (continued)

            0-ethyl O-(p-nitrophenyl) phenylphosphonothioate  (041801) plus xylene
              range aromatic  solvent  (086803)
               005905-00191

            0-ethyl O-(p-nitrophenyl) phenylphosphonothioate  (041801),  aromatic
              petroleum derivative solvent  (006501) plus  0,0-dimethyl  0-p-nitrophenyl
              phosphorothioate  (053501)
               000769-00431

            0-ethyl O-(p-nitrophenyl) phenylphosphonothioate  (041801),  aromatic
              petroleum distillate  (006601)  plus 0,0-dimethyl  0-p-nitrophenyl  phos-
              phorothioate (053501)
               009779-00131    025030-00009

            0-ethyl O-(p-nitrophenyl) phenylphosphonothioate  (041801),  0,0-dimethyl
              0-p-nitrophenyl phosphorothioate  (053501)  plus xylene (086802)
               001339-00220   001842-00268    005905-00107  013166-00010
               044317-00024

            0-ethyl  O-(p-nitrophenyl) phenylphosphonothioate  (041801),  0,0-dimethyl
              0-p-nitrophenyl phosphorothioate  (053501)  plus xylene range aromatic
              solvent  (086803)
               003442-00691   006735-00154

103.0012   3 Ib/gal emulsifiable concentrate
             0-ethyl O-(p-nitrophenyl)  phenylphosphonothioate  (041801) plus
              0,0-dimethyl 0-p-nitrophenyl  phosphorothioate (053501)
               010163-00093

             0-ethyl O-(p-nitrophenyl)  phenylphosphonothioate  (041801),  aromatic
              petroleum derivative solvent  (006501) plus 0,0-dimethyl 0-p-nitrophenyl
              phosphorothioate (053501)
               000769-00376

             0-ethyl O-(p-nitrophenyl)  phenylphosphonothioate (041801),  aromatic
              petroleum distillate (006601) plus 0,0-dimethyl 0-p-nitrophenyl phos-
              phorothioate (053501)
               007467-00060   009779-00031   019713-00057   025030-00007
               045115-00031

             0-ethyl O-(p-nitrophenyl)  phenylphosphonothioate (041801),  0,0-dimethyl
              0-p-nitrophenyl phosphorothioate (053501) plus xylene (086802)
               001339-00219   001842-00265   005905-00085   012130-00010
               013166-00007   044317-00030
           Issued:  8-15-85             111-041801-25

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                                               -191-

                                EPA Compendium of Acceptable Uses

                         0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

           Listing of Registered Pesticide Products by Formulation (continued)

           3 j.b/gal emuls.ifiable concentrate (continued)

             0-ethyl, O-(p-nltrophenyl) phenylphosphonothloate (041801), 0,0-dimethyl
              0-p-nltrophenyl phosphorothloate (053501) plus xylene range aromatic
              solvent (086803)
               000352-00406** 000876-00413   000876-00414   000876-00418
               000876-00422   000876-00424   000876-00426   000876-00430
               000876-00431   001063-00122   001191-00346*  001339-00222
               001598-00248   002935-00349   003442-00694   004841-00065
               004841-00066*  006735-00238*  007001-00351   008867-00041
               032928-00010   033722-00013*  034704-00071   037686-00001
               044605-00001
                 *jacket currently unavailable for review
                 **suspended

L04.0012   4 Ib/gal emulslflable concentrate
             0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801) plus aromatic
              petroleum distillate (006601)
               009779-00032   044215-00008

             0-ethyl O-(p-nitrophenyl) phenylphosphonothloate (041801) plus xylene
              (086802)
               001990-00487*  002737-00017   005905-00174
                 *jacket currently unavailable for review

             0-ethyl O-(p-nltrophenyl) phenylphosphonothioate (041801) plus xylene
              range aromatic solvent (086803)
               000279-02650   000876-00433   002935-00346   006735-00142
               008590-00594   019713-00130   034704-00061

             0-ethyl O-(p-nltrophenyl) phenylphosphonothioate (041801), aromatic
              petroleum distillate (006601) plus parathion (057501)
               009779-00213

105.0012   5 Ib/gal emulslflable concentrate
             0-ethyl O-(p-nltrophenyl) phenylphosphonothioate (041801) pius^-aromatic
              petroleum derivative solvent (006501)
               000769-00359

             0-ethyl O-(p-nitrophenyl) phenylphosphonothioate (041801) plus xylene
              (086802)
               000876-00234   000876-00328*  001842-00264   005905-00123
               005905-00349
                 *jacket currently unavailable for review
           Issued:   8-15-85             HI-041801-26

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                                              -192-

                                EPA Compendium of Acceptable Uses

                        0-ETHYL  O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

           Listing of Registered Pesticide Products by Formulation (continued)

           5 Ib/gal emulsifiable concentrate (continued)

             0-ethyl O-(p-nltrophenyl) phenylphosphonothioate (041801) plus xylene
              range aromatic solvent (086803)
               000352-00405** 000876-00359*  000876-00360   000876-00361
               000876-00362   000876-00363   000876-00364   000876-00365
               000876-00366   000876-00367   000876-00368   000876-00369
               000876-00370   000876-00371   000876-00372   000876-00373
               000876-00374   000876-00375   000876-00376   000876-00377
               000876-00378   000876-00379   000876-00380   000876-00381
               001386-00612   003442-00690   008590-00608   010107-00041
               019713-00121   034704-00060
                 *jacket currently unavailable  for review
                 **suspended
)999999      State  Label Registrations

              AL Reg.  No.
                009779-04760   015575-05331

              CA Reg.  No.
                005967-05161   007001-07720

              KS Reg.  No.
                002737-09563

              LA Reg.  No.
                004841-06166
            Issued:   8-15-85             111-041801-27

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                                     -193-


                     EPA Compendium of Acceptable Uses

              0-ETHYL O-(p-NITROPHENYL)  PHENYLPHOSPHONOTHIOATE

                                Appendix A-l

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

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

053501        methyl parathlon      0,0-dlmethyl 0-p-nltrophenyl phosphorothioate
              (ISO)

057501        —                    parathlon

077501        sulfur                sulfur or sulphur


— Use EPA Acceptable Common/Chemical Name
Issued:  8-15-85             IH-041801-28

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IV.  BIBLIOGRAPHY APPENDICES

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                             -194-

                            BIBGUIDE-1

              GUIDE TO USE OF THIS BIBLIOGRAPHY
1.  CONTENT OF BIBLIOGRAPHY.  This bibliography contains
    citations of all studies considered relevant by EPA in
    arriving at the positions and conclusions stated elsewhere
    in the Standard.  Primary sources for studies  in this
    bibliography have been the body of data submitted to EPA
    and its predecessor agencies in support of past regulatory
    decisions.  Selections from other sources including the
    published literature,  in those instances where they have
    been considered, will  be included.

2.  UNITS OF ENTRY.  The unit of entry in this bibliography
    is called a "study."  In the case of published materials,
    this corresponds closely to an article.  In the case of
    unpublished materials  submitted to the Agency, the Agency
    has sought to identify documents at a level parallel to
    the published article  from within the typically larger
    volumes in which they  were submitted.  The resulting
    "studies" generally have a distinct title (or at least a
    single subject), can stand alone for purposes of review,
    and can be described with a conventional bibliographic
    citation.  The Agency  has attempted also to unite basic
    documents and commentaries upon them, treating them as a
    single study.

3.  IDENTIFICATION OF ENTRIES.  The entries in this bibliography
    are sorted numerically by "Master Record Identifier," or
    MRID,  number.  This number is unigue to the citation, and
    should be used at any  time specific reference is reguired.
    It is not related to the six-digit "Accession Number"
    which  has been used to identify volumes of submitted
    studies; see paragraph 4(d)(4) below for a further explana-
    tion.   In a few cases, entries added to the bibliography
    late in the review may be preceded by a nine-character
    temporary identifier.   These entries are listed after
    all MRID entries.  This temporary identifier number is
    also to be used whenever specific reference is needed.

4.  FORM OF ENTRY.  In addition to the Master Record Identifier
    (MRID), each entry consists of a citation containing
    standard elements followed, in the case of material
    submitted to EPA, by a description of the earliest known
    submission.  Bibliographic conventions used reflect the
    standards of the American National Standards Institute
    (ANSI), expanded to provide for certain special needs.

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                         -195-

                        BIBGUIDE-2

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

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

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

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

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

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

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

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

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                                 -196-

                      OFFICE OF ffiSTIQDE PROGRAMS
                   REGISTRATION STANDARD BIBLIOGRAPHY
      Citations Considered to be Part of the Data Base Supporting
                  Registrations Under the EPN Standard


  MRID           CITATION

00002875 Frear, D.E.H.; Boyd, J.E.  (1967) Use of  Daphnia magna for the
            microbioassay of pesticides:  I.  Development of standardized
            techniques for rearing  Daphnia and preparation of  dosage-mor-
            tality curves for pesticides. Journal  of Economic Entomology.
            60(5) :1228-1236.  (Also in unpublished submission  received
            May 11, 1977 under 239-2458;  submitted  by Chevron  Chemical Co.,
            Richmond, Calif.; CDL:230225-A)

00003945 Cuthbert,  F.P., Jr.; teid, W.J., Jr.  (1962)  Laboratory Tests  of
            Compounds for Toxicity  to Larvae of  the Banded Cucumber Beetle.
            By U.S. Agricultural Research Service,  Entomology  Research Divi-
            sion.   Washington, D.C.: U.S. Dept.  of Agriculture.   (ARS-33-
            72; also in unpublished submission received on unknowi  date
            under unknown admin, no.; submitted  by  FMC Corp. ,  Philadelphia,
            Pa.; CDL:008870-B)

00022923 Hill, E.F.; Heath,  R.G.; Spann,  J.W.; et al.  (1975) Lethal Dietary
            Toxicities of Environmental Pollutants  to Birds: Special Scien-
            tific Report—Wildlife  No.  191.   (U.S.  Dept. of the Interior,
            Fish and Wildlife Service, Patuxent Wildlife Research Center;
            unpublished report)

00036935 Atkins, E.L.; Greyvood, E.A.;  Macdonald, R.L.  (1975)  Toxicity of
            Pesticides and Other Agricultural Chemicals to Honey Bees: Labo-
            ratory Studies.   By University of  California, Dept. of Entomolo-
            gy.   ?: X,  Cooperative  Extension.   (Leaflet 2287; published
            study.)

00057028 Tayfun, F.O. (1971) One-Hour Inhalation  Toxicity: Haskell  Laborato-
            ry Report No. 32-71.  (Unpublished study received  Mar 21,  1977
            under 352-338; submitted  by E.I. du Pont de Nemours & Co., Wil-
            mington, Del.; CDL:228727-B)

00066341 U.S.  Environnental  Protection Agency, Environmental Research Labo-
            ratory (1981) Acephate, Aldicarb,  Carbcphenothion, DEF, EPN,
            Ethoprop, Methyl Parathion, and  Phorate: Their Acute and Chronic
            Toxicity, Bioconcentration  Potential, and Persistence as Related
            to Marine Environments: EPA-600/4-81-023.   (Unpublished study)

00068367 E.I.  du Pont de Nemours & Company (1951) Residues of  EPN on Food
            Crops.   (Unpublished study  received on  unknown date under 352-
            1.46; CDL:231094-B)

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                                 -197-

                      OFFICE  OF BEST ICE DE  PROGRAMS
                   REGISTRATION STANDARD BIBLIOGRAPHY
      Citations Considered to be Part  of the Eat a Base Supporting
                  Registrations Under  the  EPN  Standard
 MRID           CITATION

00068437 E.I.  du Pont de Nemours &  Company  (1961) EPN 300 Insecticide: Ex-
            perinental Results.   (Reports by various sources; unpublished
            study/ including published  data,  received on unknown date under
            352-146; CDL:231099-A)

00068905 E.I.  du Pont de Nemours &  Company  (1978) Residue Analysis (1977 Re-
            sults).  (Compilation;  unpublished study received Jun 15, 1978
            under unknown admin, no.; CDL:234119-G)

00077299 Fink, R. (1976) Final Report:  Eicht-Day Dietary LC50--Mallard
            Duck: Project No. 107-128.   (Unpublished study received Aug 31,
            1976 under 876-235;  prepared by Truslow Farms, Inc., submitted
            by Velsicol Chemical Corp. , Chicago, 111.; CDL: 226817-A)

00079794 Fisher, R.L. (1978) Letter sent to J.A. Gardiner dated Aug 30,
            1978: Metabolism of  14C-EPN in  chickens.  (Unpublished study
            received on unknovn  date under  352-338; submitted by E.I. du
            Pont de Nemours & Co.,  Wilmington, Del.; CDL:236741-J)

00079807 E.I. du Pont de Nemours &  Company, Incorporated (1977) Technical
            Manual for Insecticide  Formulators: EPN Technical.   Wilmington,
            Del.: DuPont.  (Also in unpublished submission received on un-
            known date under 352-338; CDL:236741-X)

00085219 Sanders, H.O. (1972) Toxicity  of Some Insecticides to Four Species
            of Malaccstracan Crustaceans.   By U.S. Fish and Wildlife Serv-
            ice, Fish-Pesticide  Research Laboratory.   Washington, D.C.:
            USFW3.  (Technical papers of the Bureau of Sport Fisheries and
            Wildlife 66; published  study; CDL:232666-T)

00085429 E.I.  du Pont de Nemours &  Company  (1978?) Summary of Preliminary
            Studies on the Hen Metabolism of EPN at a High Dose Level.
            Summary of study 236741-L.   (Unpublished study received on un-
            knowi date under 352-338; CDL:236741-K)

00089025 E.I.  du Pont de Nemours &  Conpary  (1972) Residue Analyses of Taric
            Mix Combinations of  EPN + lannate Insecticide on Cotton.  (Un-
            published study received May 29, 1981 under 352-342; CDL:
            246524-B)

00100078 E.I.  du Pont de Nemours &  Co., Inc. (1950) Residue Data for EPN
            300 Insecticide on Various  Fruit. (Compilation; unpublished
            study received Oct 14,  1950 under 352-146; CDL:002747-D)

00100088 Anon. (19??) Residue Data  EPN  on Sveetcorn.  (Unpublished study
            received on unknown  date under  unknown admin, no.; submitted
            by ?; CDL:124392-A)

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                                 -198-

                      OFFICE OF EESTICEDE  PROGRAMS
                   REGISTRATION STANDXFD BIBLICX&APHY
      Citations Considered to be Part  of the Data Base Supporting
                  Registrations Under  the  EPN  Standard


 MRID           CITATION

00100090 E.I. du Pont de Nemours & Co., Inc. (1959) Data Supporting Revised
            Use Claims for EPN 300 Insecticide on Tonatoes.  (Unpublished
            study received Feb 26, 1959 under unknown admin, no.; CDL:
            124557-A)

00100093 Union Carbide Corp.  (1976) Acute  Toxicity of EPN (80% Active In-
            gredient)  to Bluegill Sunfish  ...f Rainbow Trout ... f and the
            Water Flea Daphnia Magna Straus.   (Unpublished study received
            Apr 26, 1976 under 876-235; submitted by VeJsicol Chemical
            Corp., Cnicago, IL; CDU223991-B)

00100099 E.I. du Pont  de Nemours & Co. , Inc. (1949) Residues, Analyses,
            Essential  Data: EPN.   (Unpublished study received Feb 10, 1950
            under 352-146; CDL:023207-C)

00101107 Averell, P.;  Norris,  M. (1948) Estimation of stall anounts of O,O-
            diethyl 0,p-nitrcphenyl thiophcsphate.   Analytical Chemistry 20
            (8):753-756.  (Also in unpublished submission received Jul 20,
            1955 under PP0032;  submitted by American Cyanamid Co., New York,
            NY; CDL:090977-G)

00109147 Chrzancwski,  R. (1977) Metabolism of 14C-EPN on Cotton Plants.
            (Unpublished study received Dec 1, 1977 under 352-338;  submitted
            by E.I. du Pont de Nemours & Co., Inc., Wilmington,  DE;  CDL:
            232389-C)

00111931 Firk, R. (1976) Final Report: Acute Oral LD5 0—Mai lard Duck:  Tech-
            nical EPN: Project No. 107-129.  (Unpublished study received
            Apr 26, 1976 under 876-235; prepared by Truslcw Farms,  Inc.,
            submitted  by Velsicol Chemical Corp., Chicago, IL; GDL:223991-A)

00145678 Dean, W. (1977) Acute Denial Toxicity (LD50) Study in Albino Rab-
            bits: Study No. 163-495.  Unpublished study prepared by Inter-
            national Research and Development Corp.   18 p.

00152760 Cox, R.; Dean,  R.;  Quander, R.; et al.  (1985) 21-day Dermal Toxici-
            ty Study in Rats:  EPN Technical: Final Report: Project No.
            2096-120.   Unpublished study prepared by Hazleton Laboratories
            America, Inc.  145 p.

00153508 Kennel]y, J.  (1985)  Study To Determine  the Ability of EPN Technical
            To Induce  Unscheduled DNA Synthesis in HeLa Cells:  Study No.:
            NCJ l/He/KF16/HE2.   Unpublished study prepared by Microtest Re-
            search Ltd.   16 p.

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                                 -199-

                      OFFICE  OF PESTICIDE  PROGRAMS
                   REGISTRATION STANDARD BIBLIOGRAPHY
      Citations Considered to be Part  of the Data Base Supporting
                  Registrations Under the  EPN  Standard
 MRID           CITATION

00153509 Kirkland, D.  (1985)  Study To Evaluate the Potential of EPN Techni-
            cal To Induce Micronuclei in  the Bone Marrow of Treated Mice:
            Study No.: N2J 1/MMT/KF19/MM1.   Unpublished  study prepared by
            Microtest Research Ltd.   31 p.

00153510 Kirkland, D.  (1985)  Study To Evaluate the Chromosome Danaging
            Potential  of EPN  Technical by Its Effects on Cultured Chinese
            Hamster Ovary (CHO) Cells Using an in Vitro  Cytogenetics Assay:
            Study No.:'NCJ 1/CHO/KF17/CH3.   Unpublished  study prepared by
            Microtest Research Ltd.   21 p.

00153511 Kennelly, J.  (1985)  Study To Detemiine the Ability of EPN-Technical
            To Induce Mutation in Four Histidine-requiring Strains of
            Salmonella typhimurium:  Study No.:  N2J 1/S/AF4/SA3.   Unpublish-
            ed study prepared by Microtest  Research Ltd. 33 p.

00158890 Osherof f, M.  (1986)  Subchronic Toxicity Study in Dogs:  [Using EPN
            Technical]:  Final Report: Project No. 2096-121.  Unpublished
            study prepared by Hazleton Labs.  America, Inc.  232 p.

00158920 Cresswell, D.;  Hopkins, R.  (1986)  [Carbon-14]-EPN: A Study of the
            Absorption,  Distribution, Metabolian and Excretion in the Rat:
            Report No. 4958-306/14.   Unpublished study prepared by Hazleton
            Laboratories Europe Ltd.  561 p.

00159372 Roberts, N.;  Phillips, C.;  Gcpinath,  C.; et al. (1986) Acute De-
            layed Neurotoxicity Study with  EPN in the Domestic Hen: Report
            No. NSA 19(a)/8646.  Unpublished study prepared by Huntingdon
            Research Centre Ltd.  50 p.

00160200 Roberts, N.;  Phillips, C. (1986) Acute Delayed  Neurotoxicity Study
            with EPN in  the Domestic Hen, Providing Additional Information
            on Recovery  Aspects: NSA 19 (b)/86335. Unpublished study pre-
            pared by Huntingdon Research  Centre Ltd.  101 p.

00160618 Kennelly, J.  (1986)  Study To Determine the Ability of EPN Technical
            To Induce Mutations to 6-Thioguanine Resistance in Mouse
            Lynphcma L5178y Cells Using a Fluctuation Ass^: Study No.
            NCJ 1/ML/KF20/ML3.  Unpublished study prepared by Microtest
            Research Ltd.  26 p.

00161799 Collins, C. (1986) EPN Technical:  13 Week Inhalation Toxicity Study
            in the Rat:  Report No. 5160-306/13.  Unpublished study prepared
            by Hazleton Laboratories Europe, Ltd.  206 p.

-------
                                   -200-

                        OFFICE OF EESTICEDE PROGRAMS
                     REGISTRATION STANt&HD BIBLIOGRAPHY
        Citations Considered to be Part of the Data Base Supporting
                    Registrations Under the EPN Standard


   MRID           CITATION

  00162934 Morseth, S. (1986) Rat Teratology Study  EPN  Technical:  Final  Re-
              port: Project No. 2096-115.   Unpublished  study prepared  by Haz-
              leton Laboratories America,  Inc.   197 p.

 00162999 Rahland, J. (1986) Detertrination of Dislodgeable Residues of EPN,
             EPN Oxon, and EPN S-ethyl fron Corn, Soybean, Cotton, Pecan,
             and Citrus Foliage (Analytical Results): Cotton Repeat: Adden-
             dum B to the Final Report: Study No. 6157-124.  Unpublished
             study prepared by Hazleton Laboratories Anerica, Inc.  89 p.

  00163019 Morseth, S. (1986) Rabbit Teratology Study EPN Technical: Final Re-
              port: Project No. 2096-116.   Unpublished  study prepared  by
              Hazleton Laboratories America,  Inc.   149  p.

 00163515 Rahland, J. (1986) Determination of the Dislodgeable Residues of
             EPN,  EPN Oxon, and EPN S-Ethyl from Corn,  Soybean, Cotton,
             Pecan, and Citrus Foliage (Analytical  Results): Stability Study:
             Interim Addendum A to the Report:  Study No. 6157-124.  Unpub-
             lished study prepared by Hazleton Laboratories Anerica, Inc.
             96 p.

  05000975 Tucker, R.K.; Haegele, M.A. (1971) Comparative acute oral toxicity
              of pesticides to six species of birds.  Toxicology and Applied
              Pharmacology 20(l):57-65.

  05008363 Hudson, R.H.; Haegele, M.A.; Tucker,  R.K. (1979) Acute oral and
              percutanecus toxicity of pesticides to mallards: correlations
              with mammalian toxicity data.   Toxicology and Applied
              Phaunacolcgy 47(3) :451-460.

  05009242 Sanders, H.O. (1969) Toxicity of Pesticides  to the Crustacean
              Gammarus lacustris:.  Washington, D.C.:   U.S.  Bureau of
              Sport Fisheries and Wildlife.  (U.S. Bureau of Sport Fisheries
              and Wildlife technical paper 25)

GS0147-001 Horwitz, W. ed. (1980) Officeial Nfethods  of Analysis of the
              Association of Official Analytical Chemists: 13th ed.
              Washington, D.C.: A.O.A.C. (Section 29.039-29.043 only.

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V.  FORMS APPENDICES

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                                                          -201-
                                                                             OMB Approval No. 2OO&0468 (Expires 12-31-83)
                  FIFRA SECTION 3(C)(2)(B) SUMMARY SHEET
                                                                                     EPA REGISTRATION NO.
  PRODUCT NAME
  APPLICANT'S NAME
                                                                                     DATE GUIDANCE DOCUMENT ISSUED
   With respect to the requirement to submit "generic" data imposed by the FIFRA section 3(C)(2)(B) notice contained in the referenced
   Guidance Document, I am responding in the following manner:
      01. I will submit data in a timely manner to satisfy the following requirements. If the test procedures I will use deviate from (or are nut
           specified in) the Registration Guidelines or the Protocols contained hi the Report! of Expert Groups to the Chemicals Group. OECO
           Chemicals Testing Programme, I endow the protocols that I will use:
                      separate page with  a  list  of the data  requirements  your company
            agrees  to satisfy.
     D 2. I haw entered into M agreement with one or more other registrants under FIFRA section 3(C)(2)(B)(ii) to satisfy the following data
           requirements. The tests, and any required protocols, w9l be submitted to EPA by:
   NAME OF OTHER REGISTRANT
                                      Attach list of  data  requirements
     D 3.  I enclose a completed "Certification of Attempt to Enter Into an Agreement with Other Registrants for Development of Data" with
           respect to the following data requirements:
     D 4. I request that you amend my registration by deleting the following uses (this option is not available to applicants for new products):
     D S. I request voluntary cancellation of the leuuuation of this product (This option a not available to applicants for new products)
REGISTRANTS AUTHORIZED REPRESENTATIVE
ETA Form 8680-1 <1fr82t
SIGNATURE
                                                                                                      DATE

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                                                                   -202-
                                                                               OMB Approval No. 20OOO468 (Expires: 12-31-83)
 (To qualify, certify ALL four items)
                                          CERTIFICATION OF ATTEMPT TO ENTER
                                      INTO AN AGREEMENT WITH OTHER REGISTRANTS
                                                FOR DEVELOPMENT OF DATA
  1. I am duly authorized to represent the following firm(s) who are subject to the require-
    ments of a Nottca under FIFRA Section 3(c)(2)(B) contained in a Guidance Document
    to submit data concerning the active ingredient:
                                                                                      GUIDANCE DOCUMENT DATE
ACTIVE INGREDIENT
                                       NAME OF FIRM
                                                                                              EPA COMPANY NUMBER
  (This firm or group of firms is referred to below as "my firm".)
  2. My firm is wilting to develop anfl submit the data as required by that Notice, if necessary. However, my firm would prefer to enter
    into an agreement with ori^br rrfore other registrants to develop jointly, or to share in the cost of developing, the following required
    items or data:
 3. My firm has offered in writing to enter into such an agreement. Copies of the offers are attached. That offer was irrevocable and included an offer to be
    bound by an arbitration decision under FIFRA Section 3(c)(2)(B)(iii) if final agreement on all terms could not be reached otherwise. This offer was made
    to the following firm(s) on the following date(s):
                                      NAME OF FIRM
                                                                                                 DATE OF OFFER
 However, none of those firm(s) accepted my offer.
 4. My firm requests that EPA not suspend the registration(s) of my firm's product(s), if any of the firms named in paragraph (3) above
   have agreed to submit the data listed in paragraph (2) above in accordance with the Notice, t understand EPA will promptly inform
   me whether my firm must submit data to avoid suspension of its registration(s) under FIFRA Section 3(c)(2)(B). (This statement
   does not apply to applicants for new products.)  I give EPA permission to disclose this statement upon request.
 TYPED NAME
                                                     SIGNATURE
                                                                                                       DfcTE
EPA Form 8S8O« (1O-S2)

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                                          -203-
EPA Reg. No.
PRODUCT SPECIFIC DATA REPORT




             Date
Guidance Document for
Registration
Guideline No.
§158.120
PRODUCT
CHEMISTRY
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
Name of Test

Identity of
ingredients
Statement of
composition
Discussion of
foimation of
ingredients
Preliminary
analysis
Certification of
limits
Analytical nethods
for enforcement
limits
Color
Physical state
Odor
Melting point
Boiling point
Density, bulk-
density, or
specific gravity
Solubility
Vapor pressure
Dissociation
constant
Oct ano]/wa ter
partition
coefficient
pH
Test not
required
for my
product
listed
above
(check
below)


















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


















Submit-
ting
Data
(At-
tached )


















(For EPA Use Only)
Accession Numbers
Assigned



















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-204-
Regi stration
Guideline No.
63-13
63-14
63-15
63-16
63-17
63-18
63-19
63-20
63-21
§158.135
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
Name of Test
Stability
Oxidizing/reducing
reaction
Fl amenability
Explodability
Storage stability
Viscosity
Miscibility
Corrcs ion
characteristics
Dielectric break-
down voltage

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
















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
















Submit-
ting
Data
(At-
tached )
















(For EPA Use Only)
Accession Numbers
Assigned

















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                                            -205-

                      FORMULATOR'S EXEMPTION STATEMENT
                              (40 CFR 152.85)

 EPA File Symbol/Reg. No. 	Product Name

 Applicant's Name and Address 	
As an authorized  representative of the applicant for registration of  the
product  identified above, I hereby certify that:

   (1)   This product contains the active ingredient(s): 	
   (2)  Each active ingredient listed in paragraph (1) is present solely
as the result of the incorporation into the product (during formulation or
packaging) of another product which contains that active ingredient, which
is registered under FIFRA sec. 3, and which is purchased by us from another
producer.

   (3)  Indicate by circling (A)  or (B)  below which paragraph applies:

   (A)  An accurate Confidential  Statement of Formula (EPA Form 8570-4)  for
   the above identified product is attached to this statement.  That formula
   statement indicates, by company name, registration number and product
   name, the source of the active ingredient (s)  listed in paragraph (1).
   (B)  The Confidential Statement of  Formula dated _ on file with
   the EPA is complete,  current and accurate and contains  the information
   required on the current CSF Form No. 8570-4.  The registered source(s)
   of the active ingredient(s) listed  in paragraph (1)  is/are listed  below:

   Active ingredient                Source:  Product name  and Reg. No.
                          Signature

  Hate 	       Title



  EPA Form            (April 1985)

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