State Environmental Protection Agency Of.cce of Pettic dec «nd Toxic ubstance* OMice of Pestiode Programs (TS-766C) Washington. DC 2O46O xTfc Pesticide Fact Sheet Name of Chemical: Reason for Issuanoe: Date Issued: JAN - Fact Sheet Number: Phosphamidon Registration Standard 1988 154 Description of Chemical Common Name: Phosphamidon Chemical Name: ?-chloro-3-(diethylamino)-l-methyl-3- oxo-1-propenyl dimethyl phosphate Other Chemical Nomenclature: Trade Names: dimethyl phosphate ester 2-chloro-N,N-diethyl-3- hydroxycrotonamide; 2-chloro-2-diethylcarbamoyl- 1-methylvinyl dimethyl phosphate; O,0-dimethyl-O-(2-chloro- 2-diethylcarbamoy1-1- methylvinyl) phosphate Apamidon; C570; Ciba 570; Dimecron; Dixon; Dimenox Chemical Class: Organophosphate Empirical Formula: CioH^qClNO5P Chemical Abstracts Service (CAS) Nos.: 13171-21-6 [(E)-+(Z)-isomers] 23783-98-4 [(Z)-isomerl 297-99-4 [(E)-isomer] OPP Shaughnessv No.: 018201 Pesticide Type: Systemic insecticide/acaricide Year of initial Registration: 1963 U.S. and Poreian Producers: Ciba-Geigy Corp., USA Use Patterns and Formulations Application sites: terrestrial food crops — apple; apple (nonbearing) ; broccoli; cantaloupe; cauliflower; cotton; cucumber; grapefruit; lemon; orange; peppers; potato; sugarcane; tangerine; tomato; walnut; watermelon. ------- —2— Types of Formulation: Phosphamidon is marketed as an 8 lb ai/gal SC/L (soluble concentrate! liquid), and is formuldted from a single 89.5% technical product. Types/Methods of Application: Phosphamidon is applied by ground and aeriaL application. 3. Science Findings Summary Science Statements : Phosphamidon is an organophosphate compound. The Agency has no valid acute toxicity studies for phosphamidon, although the Agency believes that phosphamidon is highly toxic. No valid subchronic studies are available for phosphamidon. A 2-year rat feeding study showed toxic signs of choitnesterase inhibition activity in serum and brain, decreased body weights, erythrocyte counts, hemoglobin levels and, necrotic changes in the stomach and other organs. Studies on the toxic effects of phosphamidon in nonrodent species are not available. The submitted oncogenicity data are considered inadequate to assess the oncogenic potential of phosphamidon. Sufficient developmental toxicity data are available to satisfy the regulatory requirements in two species. Based on these data the Agency concluded that phosphamidon did not demonstrate any significant developmental toxic effects. The available 2—generation rat reproduction study satisfies this requirement. No data are available to evaluate the mutagenic potential of phosphamidon. No data on the metabolic pathway of phosphamidon are available. Phosphamidon is acutely and subacutely very highly toxic to a variety of avian species and can be lethal to birds through dermal exposure. In additiQn, available information indicate that delayed mortality of birds occurs after applications of phosphamidon (in some cases up to several weeks). Since available information suggests that phosphamidon may have a relatively short half—life, it is possible that some degradate is toxic to birds. Based upon the fish and wildlife data available, it is observed that technical phosphamidon is very highly toxic to both coidwater and warmwater fish species, aquatic invertebrates, and mammals. Available data indicate that phosphamidon is highly toxic to honey bees, predaceous mites, parasitic wasps, and predaceous beetles. ------- —3— Chemical Characteristics : Physical/chemical properties of pure phosphamidon and of the technical phosphamidon. Color: Colorless (PAI*), slightly amber oil (T*) Physical State: Liquid (PAl) Odor: Odorless, faint, mild (PAl) Melting Point: Liquid at room temperature Boiling Point: 160 °C, 1.5 mm (PAr) Density: 1.2 at 20 °C (PAl) Solubility: Miscible with water, alcohol, and ketones. Highly solub1 e in aromatic and chlorinated hydrocarbons, esters and ethers. Solubility in hexane is 3.23 g/lOO g 25°C (PAl) Vapor Pressure: 2.5 x lO- mm Hg at 20 °C (PAl) Octanol/Water Partition Coefficient: Log P = 0.8 (PAl) Stability in water: Half—life at 2 ppm and 38 °C is 70 hours at pH 9.1 and > 300 hours at pH 1.1 (PAl). Half—life (in days) of phosphamidon in buffered media (T): Temperature 23 °C 45 °C 4 74 6.6 7 13.8 2.1 10 2.2 0.14 Toxicology Characteristics : Acute oral: Data gap Acute dermal: Data gap Acute inhalation: Data gap Primary dermal irritation: Data gap Primary eye irritation: Data gap Acutedelayed neurotoxicity: Data gap Subchronic oral (nonrodent): Data gap ** Chronic feeding (nonrodent): Data gap Oncogenicity : Data inadequate to assess oncogenic potential, Study required in the mouse. Metabolism: Data gap Developmental Toxicity: Rabbit - Maternal NOEL = 3 mg/kg Maternal LEL = 10 mg/kg Developmental NOEL = > 10 mg/kg Rat — Maternal NOEL = 0.5 and 1 mg/kg Developmental NOEL = 2 mg/kg *pAI = Pure Active Ingredient, T = Technical ** Not required if an acceptable chronic study is submitted. ------- —4— Reproductive effects: Rat — Parental F’OEL = 30 ppm (1.5 mq/kg/day) Parental LEL 50 ppm (2.5 mg/kg/day) Reproductive/Developmental NOEL = 5 ppm (0.25 mg/kg/day) Reproducti ye/Developmental LEL = 30 ppm (1.5 mg/kg/day) Mutagenicity: Data gap Physiological and Biochemical Characteristics: Metabolism and persistence in plants and animals The metabolism of phosphamidon in plants and animals is not adequately understood. Residues of [ 14 C] phosphamidon were identified and quantitatively determined only in immature bean plants. No edible livestock tissues (other than milk) were analyzed for residues, and residues were not characterized sufficiently in livestock. No poultry data were submitted. The available plant metabolism data indicate that phosphamidon degrades rapidly when applied directly to the leaves of very young “two—leaf stage” bean plants. The limited available ruminant metabolism data indicate that phosphamidon is degraded rapidly in animals, with most of the metabolic compounds being excreted in the urine. Available data support the established tolerances for residues of phosphamidon including all of its related cholinesterase—inhibiting compounds (as currently known) in or on the raw agricultural commodities (RACs) potatoes, tomatoes, cucumbers, cottonseed, and sugarcane. Note, however, that these tolerances, including the residue definition, will be reassessed upon receipt of the requested plant metabolism studies. Ultimately, the tolerance definition will be changed to list specific metabolites. Environmental Characteristics : Available data are not sufficient to allow the Agency to fully assess the environmental fate of phosphamidon. The available data suggest that phosphamidon is readily susceptable to hydrolysis. Phosphamidon appears to be relatively short lived in aerobic soil. N,N—diethyl—2-chloroacetoacetamide and N—ethyl—2—chloroacetamide were identified as the two major nonvolatile degradates, but the characterization of degradates has not been completed. Phosphamidon residues are considered to be highly mobile in soil. However, the relative mobilities of the parent compound and its degradates have not been adequately defined. Available data are not adequate to fully assess the potential of phosphamidon to contaminate ground water. ------- —5— Ecological Characteristics: Avian Species Technical phosphamidon is very highly acutely toxic to birds as demonstrated by both acute and dietary studies. Subacute dietary studies demonstrate that there is a range of toxicity from 24 ppm (bobwhite quail) to 712 ppm (mallard duck). Available data indicate that phosphamidon can be toxic to birds through contact with head, feet or through contact with sprayed foliage. Data indicate that small doses picked up from perches or applied to the feet of birds can be lethal. Special tests are being required to determine the dermal toxi city of phosphamidon to birds. Avian reproduction studies for phosphamidon are not available. There are no data available on the toxicity of degradates of phosphamidon to birds. Because delayed mortality is an indicated adverse effect of phosphamidon on birds, and because substantial reduction of populations of songbirds have occurred several weeks after phosphamidon applications to forests, it is possible that degradation products of phosphamidon can result in such effects. Aquatic Organisms Acceptable acute toxicity tests with technical phosphamidon indicate that phosphamidon is highly toxic to fish. The acute toxicity tests with freshwater invertebrates indicate that phosphamidon is very highly acutely toxic to aquatic invertebrates. There are no acceptable data evaluating the toxicity of technical phosphamidon to estuarine and marine organisms. Phosphamidon may reach estuarine environments from its use on citrus orchards. Acute studies on the toxicity of phosphamidon to estuarine and marine invertebrates are required. Aquatic invertebrate life cycle studies are required to support the agricultural use applications. Wild Mammal Toxicity There are no adequate data with which to assess the toxicity of phosphamidon to mammals. The only study available, which suggests a lethal dose of 18 mg/kg in the deer mouse, indicates that phosphamidon may be highly toxic to wild mammals. Although the Agency can draw no conclusions regarding the potential toxicity of phosphamidon to mammals, a wild mammal toxicity study is not being required at this time. However, if the acute mammalian studies required in the Toxicology Section indicate a rat acute toxicity < 5 mg/kg then a wild mammal toxicity study will be required. ------- —6— Non—target Insects Available data indicate that phosphamidon is highly toxic to honey bees, predaceous mites, parasitic wasps, and predaceous beetles. Tolerance Reassessment Tolerances (expressed as phosphamidon) for residues of the insecticide phosphamidon (2—chloro—2—diethylcarbamoyl- 1—methylvinyl dimethyl phosphate) including all of its related cholinesterase—inhibiting compounds have been established in or on various raw agricultural commodities (40 CFR 180.239). Because of the extensive residue chemistry and toxicology data gaps, the Agency cannot complete a tolerance reassessment. 4. Required Labeling and Regulatory Position Summary Restricted Use Classification All currently registered products containing phosphamidon have been classified for Restricted Use (40 CFR 162.31) due to the acute dermal toxicity to humans and residue effects on avian and mammalian species. Endangered Species Labeling Refer to PR Notice 87—5, issued May 1, 1987, for endangered species labeling statements for all end—use products containing phosphamidon for use on cotton. It is the Agency’s position that in order to remain in compliance with FIFRA, all products containing phosphamidon must include labeling which requires compliance with the following precautionary measures, pending receipt and evalu&tion of additional data which will allow the Agency to fully assess the potential to induce adverse effects. Protective Clothing, Equipment and Work Safety Statements The use of maximum full body protective clothing/equipment by mixers/loaders/applicators, and by field workers entering treated fields prior to the end of the 48 hour reentry interval is required. ------- —7— Reentry Interval A 43—hour reentry inter ia1 is required for all agricultural uses of phosphamidon. In addition, the use of protective clothing is required for early reentry into treated areas. Tolerances No tolerances or significant new food uses will be granted until the Agency has received sufficient data to evaluate the dietary exposure to phosphamidon. 5. Summary of Major Data Gaps Toxicology Date Due * Acute Oral Toxicity 9 Months Acute Dermal Toxicity 9 Months Acute Inhalation Toxicity 9 Months Primary Eye Irritation 9 Months. Primary Dermal Irritation 9 Months Dermal Sensitization 9 Months Acute Delayed Neurotoxicity (hen) 12 Months Subchronic 90-day feeding (nonrodent)** 18 Months Subchronic 21-Day Dermal 12 Months Chronic Toxicity (nonrodent) 50 Months Oncogenicity (mouse) 50 Months Mutagenicity (Gene Mutation, Chromosomal Aberration and Direct DNA Damage and Repair Studies) 9 Months Metabolism (rats) 24 Months Environmental Fate/Exposure Hydrolysis 9 Months Photodegradat ion In water 9 Months In soil 9 Months In air 9 Months Metabolism Aerobic Soil 27 Months Anaerobic Soil 27 Months Mobility Leaching and Adsorption/Desorption 12 Months Laboratory Volatility 12 Months Dissipation Studies - Field Soil Dissipation 27 Months Confined Accumulation Study 39 Months Fish Accumulation Study 12 Months * Due date is measured from the date of receipt of Standard by the registrant, unless otherwise indicated. ** Not required if an acceptable chronic study is submitted. ------- —8-- Environmental Fate/Exposure (cont’d) Date Due* Spray Jrift Droplet Size Spectrum 24 Months Drift Field Evaluation 24 Months Ecological Effects Acute Avian Oral Toxicity (Degradate) 9 Months Acute Avian Dietary Toxicity (Degradate) - 9 Months Avian Reproduction 24 Months Avian Field Testing (Mammals, Birds) 24 Months Special Avian Testing (Dermal Toxicity) 6 Months - (acceptable protocol) Acute Toxicity to Estuarine and Marine Organisms 12 Months Fish Early Life Stage and Aquatic Invertebrate Life cycle 15 Months Aquatic Residue Monitoring 6 Months - (acceptab]e protocol) Residue chemistry Nature of Residues (Plants, Livestock) 18 Months Residue Analytical Method (Plant, Animal) 15 Months Storage Stability 18 Months Magnitude of Residues (Field crops) 18 Months 6. Contact Person at EPA William H. Miller, (PM—16) Insecticide-Rodenticide Branch (TS-767) 401 M Street S.W. Washington, D.C. 20460 Tel. No. (703-557—2600 DISCLAIMER: The information presented in this chemical information Fact Sheet is for informational purposed only and may not be used to fulfill data requirements f or pesticide registration and reregistration. * Due date is measured from the date of receipt of Standard by the registrant, unless otherwise indicated. ------- |