United States
                 Environmental Protection
                 Agency	
                        Prevention, Pesticides
                        And Toxic Substances
                        (7508C)	
EPA-738-F-04-008
July 2004
                 R.E.D.   FACTS
     Pesticide
Reregistration
                 Ziram
     All pesticides sold or distributed in the United States must be registered
by EPA, based on scientific studies showing that they can be used without
posing unreasonable risks to people or the environment.  Because of advances
in scientific knowledge, the law requires that pesticides which were first
registered before November 1, 1984, be reregistered to ensure that they meet
today's more stringent standards.
                      In evaluating pesticides for reregistration, EPA obtains and reviews a
                 complete set of studies from pesticide producers, describing the human health
                 and environmental effects of each pesticide. To implement provisions of the
                 Food Quality Protection Act of 1996, EPA considers the special sensitivity of
                 infants and children to pesticides, as well as aggregate exposure of the public
                 to pesticide residues from all sources, and the cumulative effects of pesticides
                 and other compounds with common mechanisms of toxicity. The Agency
                 develops any mitigation measures or regulatory controls needed to effectively
                 reduce each pesticide's risks.  EPA then reregisters pesticides that meet the
                 safety standard of the FQPA and can be used without posing unreasonable
                 risks to human health or the environment.

                      When  a pesticide is eligible for reregistration, EPA explains the basis for
                 its decision in a Reregistration Eligibility Decision (RED) document. This fact
                 sheet summarizes the information in the RED document for Ziram one of four
                 chemicals in reregistration case 2180.

   Use Profile        Ziram is an agricultural fungicide registered to control fungal diseases on a
                 wide range of crops including stone fruits, pome fruits, nut crops, vegetables and
                 commercially grown ornamentals. In addition, it is formulated as a rabbit
                 repellent for outdoor foliar applications to ornamentals and as an additive in
                 industrial adhesives, caulking, and latex paints. The total annual domestic use of
                 ziram is approximately 1.9 million pounds of active ingredient.
   Regulatory        Ziram was first registered in the United States in 1960 as a broad spectrum
       History   use fungicide to control the scab in apples and pears, leaf curl in peaches, and
                 anthracnose and early blight in tomatoes. In 1981, additional uses were added to
                 the label for controlling leaf blight and scab in almonds, shot-hole in apricots,
                 brown rot and leaf spot in cherries, scab and anthracnose in pecans, and leaf spot,
                 rust and powdery mildew in ornamentals. Other registered uses of ziram include
                 homeowner application on residential ornamentals as a rabbit repellent and

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                   industrial application as a preservative in exterior latex paint, caulking, sealants
                   and wall boards.

Human Health   Toxicity
    Assessment         The mechanism of toxicity for ziram has not been fully investigated;
                   however the primary target organs appear to be the nervous system, liver, and
                   thyroid. Ziram has moderate acute toxicity. It has been placed in a toxicity
                   category II/III for oral and dermal exposure, in category II for inhalation
                   exposure, in category I for eye irritation, and in category IV for skin irritation.
                   Ziram is a moderate skin sensitizer, and is classified as "suggestive of
                   carcinogenicity" to humans.

                   Dietary Exposure (Food and Water)
                         EPA has assessed dietary risk by estimating exposure to ziram residues
                   from consumption of food and drinking water.  Both chronic and acute food
                   risks, as measured by the Population Adjusted Doses (PAD) are below the
                   Agency's level of concern. Since ziram residues are primarily found on the
                   surface of the fruit and are not systemic in nature, applying a washing
                   reduction factor (0.15) to the acute residues was a practical way to refine the
                   residues in fruits. When a washing reduction factor of 0.15 was applied to the
                   residues of all commodities (except nuts and berries) the maximum acute
                   dietary estimates were below the Agency's level of concern for all population
                   subgroups. The chronic  (non-cancer) food exposures, even without applying
                   the washing reduction factor were below the level of concern for  all population
                   subgroups. Drinking water risk estimates are based on  surface and
                   groundwater screening models. The PRZM/EXAMS and the SCI-GROW
                   models were used on surface and ground water respectively. The  drinking
                   water level of comparison (DWLOCs) for all population subgroups, are higher
                   than the surface and groundwater estimated drinking water concentration
                   (EDWC). Therefore, the chronic and acute drinking water exposures are not of
                   concern to the Agency.

                   Aggregate Risk
                         Under the Food Quality Protection Act of 1996, the Agency considers
                   contributions to risk from various exposure sources, specifically  food, drinking
                   water, and non-occupational sources. Residential exposure and risk  from the use
                   of ziram was limited to short-term exposure scenarios (dermal and inhalation)
                   because intermediate-term and chronic residential exposure to ziram from the
                   rabbit repellent and its use in  paint are not expected to occur.

                   Occupational and Residential Exposure
                         Occupational exposure is of concern to EPA for workers handling ziram in
                   agricultural settings and commercial painters. Workers can be exposed during
                   mixing/loading and applying  formulations containing ziram on agricultural,

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                   ornamental and commercial/industrial settings or re-entering the treated areas.
                   Risk for all of these potentially exposed populations is measured by a Margin of
                   Exposure (MOE), which determines how close the exposure comes to a No
                   Observable Adverse Effect Level (NOAEL). Generally, MOEs greater than 100
                   are not of concern.

                         Agricultural workers are primarily exposed to the dry flowable, liquid, and
                   wettable powder formulations. Both dermal and inhalation exposures are expected
                   to mixers, loaders, and applicators. The MOEs for agricultural workers ranged
                   from 8 to 170 while the target MOE was 100. The proposed mitigation is
                   expected to result in an acceptable level of risk for agricultural workers.

                         EPA's residential risk assessment indicates concern from outdoor use of
                   latex paints usually applied either with an airless sprayer or a brush. As a result,
                   dermal and inhalation exposures can result to homeowners. Only short-term
                   exposures were calculated because the Agency does not believe that homeowners
                   who apply paints with ziram will be exposed to the product for more than seven
                   days. Lowering the concentration of ziram in paints should result in acceptable
                   levels of risk. The Agency applied an uncertainty factor of 100 along with a
                   FQPA safety factor of 3x for a target MOE of 300. This additional factor was
                   applicable due to the  quantitative evidence of increased susceptibility in the
                   developmental neurotoxicity study in rats. The combined dermal and inhalation
                   MOEs are 74 for the  airless sprayer and 351 for the paint brush.

                   Tolerances
                         The tolerances for ziram and the other dithiocarbamates are enforced by a
                   common moiety method that determines carbon disulfide. The Agency is
                   recommending that the tolerances for ziram and all  other dithiocarbamates be
                   changed to be expressed in terms of carbon disulfide.   This recommended change
                   in tolerance  expression allows harmonization of US tolerances with Codex
                   MRLs.

                         Tolerances (refer to 40 CFR § 180.116) or maximum residue limits are
                   summarized here. There are approximately 41 proposed revocations and 7
                   proposed new tolerances for ziram. The majority of the tolerances have remained
                   the same while some have decreased.

Environmental  Environmental Fate
    Assessment        The major routes of dissipation of ziram are hydrolysis, photodegradation
                   and aerobic  soil metabolism. Ziram's high susceptibility to degradation under
                   neutral and acidic environments reduces residues of ziram significantly in soil and
                   water, thereby minimizing the probability of prolonged exposure of terrestrial and
                   aquatic  organisms to  the chemical.

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                    Ecological Effects
                          EPA has identified ecological risks of concern from ziram use, particularly
                    to birds, mammals, and aquatic organisms. Ziram showed low acute toxicity for
                    mammals, is moderately toxic to avian species and highly toxic to aquatic
                    organisms. Exposure is determined by modeling residue concentrations on
                    foodstuffs for terrestrial animals and in water for aquatic organisms.

Risk Mitigation  To mitigate risks to homeowners and commercial painters:
                               Reduce the concentration of ziram in latex paints from 3% to 1%.

                    To mitigate risks to agricultural workers:
                          •    Upgrade personal protective equipment (PPE) for mixer/loaders of
                               liquid formulations from baseline to minimal.
                          •    Require all wettable powder formulations to be packaged in water
                               soluble bags.
                               Require pilots to use planes with enclosed cockpits when applying
                               aerially.
                          •    Cancel aerial applications on blackberries, blueberries, apples grown
                               East of the Rockies, cherries grown East of the Rockies, grapes
                               grown East of the Rockies, peaches grown East of the Rockies,
                               nectarines, pears, pecans, and tomatoes.

                    To mitigate ecological risks:
                               Reduce application rates on apples, cherries grown East of the
                               Rockies, pears, nectarines, and peaches grown West of the Rockies.
                          •    Reduce the maximum numbers of applications to apricots, cherries,
                               nectarines, peaches, and pecans.

Additional Data        EPA is requiring the following additional generic studies for Ziram to
       Required  confirm its regulatory assessments and conclusions:
                          •    830.7840                    Additional water solubility  studies
                                                            using column elution or shake  flask
                                                            method
                               830.1750                    Certification of Limits
                          •    830.1620                    Description of Product on Process
                               830.7050                    UV/Visible Absorption
                          •    835.4100                    Aerobic soil metabolism with one
                                                            soil type near neutral pH
                          •    835.6100                    Terrestrial field dissipation - upgrade
                                                            existing study or submit new study

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                             •     850.1300                     Chronic toxicity study for freshwater
                                                               aquatic invertebrates
                             •     850.1350                     Chronic toxicity study for
                                                               estuarine/marine aquatic
                                                               invertebrates
                                  850.1400                     Early Life Stage Freshwater Fish
                                  850.1450                     Early Life Stage Estuarine Fish
                             •     850.1500                     Fish life cycle study for freshwater
                                                               and estuarine/marine fish
                             •     850.2300                     Avian reproduction with mallard
                                                               duck
                             •     850.4225                     Seedling Germination and Seedling
                                                               Emergence
                                  850.4250                     Vegetative Vigor
                                  850.4400                     Aquatic plant toxicity study (Tier 2)
                             •     860.1300                     Nature of residue - plants, livestock
                                                               and processed food/feed
                                                               commodities
                                  860.1500                     Additional residue data required for
                                                               blackberries, blueberries, grapes, and
                                                               tomatoes
                             •     860.1540                     Additional reduction of residue data
                                                               for orchard fruits, including washing
                                                               and processing studies (cooking data
                                                               suggested)
                             •     870.3465                     90-day inhalation study in rats
                             •     870.5395                     In-vitro Mammalian Cytogenetics
                                                               Tests
                             •     870.6300                     Morphometric analyses of brain
                                                               tissues and statistical analyses of
                                                               neurobehavioral data in the
                                                               developmental neurotoxicity study
                             •     870.7485                     Metabolism and pharmacokinetics
                                                               study in rats
                             The Agency also is requiring product-specific data including product
                       chemistry and acute toxicity studies, revised Confidential Statements of
                       Formula (CSFs), and revised labeling for reregistration.
 Product Labeling         All Ziram end-use products must comply with EPA's current pesticide
Changes Required   product labeling requirements and with the following.  For a comprehensive
                       list of labeling requirements, please see the Ziram RED document.

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 Regulatory
 Conclusion
   For More
Information
      The use of currently registered products containing Ziram in accordance
with approved labeling will not pose unreasonable risks or adverse effects to
humans or the environment. Therefore, all uses of these products are eligible
for reregistration.
      Ziram products will be reregistered once the required product-specific
data, revised Confidential Statements of Formula, and revised labeling are
received and accepted by EPA.

      EPA is requesting public comments on the Reregistration Eligibility
Decision (RED) document for Ziram during a 60-day time period, as
announced in a Notice of Availability published in the Federal Register.  To
obtain a copy of the RED document or to submit written comments, please
contact the Pesticide Docket, Public Information and Records Integrity Branch,
Information Resources and Services Division (7502C), Office of Pesticide
Programs (OPP), US EPA, Washington, DC 20460, telephone
703-305-5805.
      Electronic copies of the RED and this fact sheet are available on the
Internet. See http://www.epa.gov/pesticides/reregistration/status.htm.
      Printed copies of the RED and fact sheet can be obtained from EPA's
National Service Center for Environmental Publications (EPA/NSCEP), PO
Box 42419, Cincinnati, OH  45242-2419, telephone 1-800-490-9198; fax 513-
489-8695.
      Following the comment period, the Ziram RED document also will be
available from the National Technical Information Service (NTIS), 5285 Port
Royal Road, Springfield, VA 22161, telephone 1-800-553-6847, or 703-605-
6000.
      For more information about EPA's pesticide reregistration program, the
Ziram RED, or reregistration of individual products containing Ziram, please
contact the Special Review and Reregistration Division (7508C), OPP, US
EPA, Washington, DC 20460, telephone 703-308-8000.
      For information about the health effects of pesticides, or for assistance in
recognizing and managing pesticide poisoning symptoms, please contact the
National Pesticide Information Center (NPIC). Call toll-free 1-800-858-7378,
from 6:30 am to 4:30 pm Pacific Time, or 9:30 am to 7:30 pm Eastern
Standard Time, seven days a week.  Their internet address is
http://npic.orst. edu.

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