Reregistration Eligibility Decision
for Aliphatic Alcohols
<^
PRO^°
March 2007
s
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?/EPA
United States
Environmental Protection
Agency
Prevention, Pesticides
and Toxic Substances
(7508P)
EPA 738-R-07-004
Reregistration
Eligibility Decision
for Aliphatic Alcohols
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Reregistration Eligibility Decision (RED) for
Aliphatic Alcohols
ListD
Case No. 4004
Approved by:
Date:
Debra Edwards, PhD., Director
Special Review and Reregistration Division
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TABLE OF CONTENTS
Abstract v
I. Introduction 1
II. Chemical Overview 1
A. Regulatory History 1
B. Chemical Identification 2
III. Summary of Aliphatic Alcohols Risk Assessments 4
A. Human Health Risk Assessment 4
B. Environmental Risk Assessment 6
1. Environmental Fate and Transport 7
2. Ecological Risk Assessment 8
IV. Risk Management, Reregistration, and Tolerance Reassessment Decision 14
A. Determination of Reregistration Eligibility 14
B. Public Comment Period 15
C. Regulatory Position 15
1. Regulatory Rationale 15
2. Endocrine Disrupter Effects 16
3. Endangered Species 16
D. Labeling Requirements 17
V. What Registrants Need to Do 17
A. Manufacturing Use Products 18
1. Additional Generic Data Requirements 18
2. Labeling for Manufacturing-Use Products 18
B. End-Use Products 18
1. Additional Product-Specific Data Requirements 18
2. Labeling for End-Use Products 18
C. Labeling Changes Summary Table 19
11
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Glossary of Terms and Abbreviations
ai Active Ingredient
CFR Code of Federal Regulations
CSF Confidential Statement of Formula
DCI Data Call-In
ED WC Estimated Drinking Water Concentration
EEC Estimated Environmental Concentration
EPA Environmental Protection Agency
FDA Food and Drug Administration
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA Federal Food, Drug, and Cosmetic Act
FQPA Food Quality Protection Act
GENEEC Tier I Surface Water Computer Model (Estimated Aquatic Environmental Concentrations)
LC50 Median Lethal Concentration. A statistically derived concentration of a substance that can be expected
to cause death in 50% of test animals. It is usually expressed as the weight of substance per weight or
volume of water, air or feed, e.g., mg/1, mg/kg or ppm.
LD50 Median Lethal Dose. A statistically derived single dose that can be expected to cause death in 50% of
the test animals when administered by the route indicated (oral, dermal, inhalation). It is expressed as
a weight of substance per unit weight of animal, e.g., mg/kg.
LOC Level of Concern
LOAEL Lowest Observed Adverse Effect Level
mg/kg/day Milligram Per Kilogram Per Day
mg/L Milligrams Per Liter
MRID Master Record Identification (number). EPA's system of recording and tracking studies submitted.
MUP Manufacturing-Use Product
N/A Not Applicable
NOAEL No Observed Adverse Effect Level
OPP EPA Office of Pesticide Programs
ppb Parts Per Billion
PPE Personal Protective Equipment
ppm Parts per Million
RED Reregistration Eligibility Decision
REI Restricted Entry Interval
RQ Risk Quotient
TGAI Technical Grade Active Ingredient
UV Ultraviolet
WP S Worker Protection Standard
ill
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ALIPHATIC ALCOHOLS TEAM
Office of Pesticide Programs:
Health Effects Risk Assessment
Elissa Reaves
Shanna Recore
Yvonne Barnes
Ecological Fate and Effects Risk Assessment
Colleen Flaherty
Silvia Termes
Biological and Economics Analysis Assessment
Jihad Alsadek
Jenna Carter
Art Grube
Registration Division
Tony Kish
Risk Management
Kevin Costello
Tom Moriarty
Kimberly Nesci
IV
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Abstract
The Environmental Protection Agency (EPA or the Agency) has completed the human
health and environmental risk assessments for the Aliphatic Alcohols case 4004 and is issuing its
risk management decision. Currently, case 4004 consists of four active ingredients. Three of
these active ingredients, 1-octanol, 1-decanol and a mixture of aliphatic alcohols described as
"fatty alcohols," are used as plant growth regulators on tobacco. The fourth, 1-dodecanol (also
known as lauryl alcohol), is registered as a Lepidopteran pheromone/sex attractant in pear and
apple orchards.
A tolerance reassessment was performed in 2002 for the use of 1-dodecanol as a
pheromone. In that assessment of potential human exposure and dietary risk, the Agency
concluded, "the tolerance exemption for Lepidopteran pheromones has been reassessed and is in
compliance with the FQPA ." Neither a handler nor post-application (reentry) occupational
assessment has been conducted for any uses of aliphatic alcohols of case 4004, because no
dermal, oral, or inhalation endpoints of toxicological concern have been identified.
The potential for ecological risk from the pheromone use and from the growth-regulator
uses is considered in this document. The ecological risk assessment identifies no ecological risks
of concern from the use of aliphatic alcohols.
The risk assessments, which are summarized below, are based on the review of the
required target database supporting the use patterns of currently registered products. After
considering the potential risks identified, EPA has determined that aliphatic alcohol-containing
products are eligible for reregi strati on. That decision is discussed fully in this document.
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I. Introduction
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988
to accelerate the reregi strati on of products with active ingredients registered prior to November 1,
1984. The amended Act calls for the development and submission of data to support the
reregi strati on of an active ingredient, as well as a review of all submitted data by the U.S.
Environmental Protection Agency (referred to as EPA or "the Agency"). Reregi strati on involves
a thorough review of the scientific database underlying a pesticide's registration. The purpose of
the Agency's review is to reassess the potential risks 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 or not the pesticide meets the "no unreasonable adverse effects" criterion
of FIFRA.
This document summarizes EPA's human health and ecological risk assessments and
reregi strati on eligibility decision (RED) for aliphatic alcohols. The document consists of six
sections. Section I contains the regulatory framework for reregistration; Section II provides an
overview of the chemical and a profile of its use and usage; Section III gives an overview of the
human health and environmental effects risk assessments; Section IV presents the Agency's
decision on reregistration eligibility and risk management; and Section V summarizes the label
changes necessary to implement the risk mitigation measures outlined in Section IV. Finally, the
Appendices list related information, supporting documents, and studies evaluated for the
reregistration decision. The risk assessments for aliphatic alcohols and all other supporting
documents are available in the Office of Pesticide Programs (OPP) public docket
(http://www.regulations.gov) under docket number EPA-HQ-OPP-2007-0134.
II. Chemical Overview
A. Regulatory History
Reregistration case number 4004 consists of straight chain aliphatic alcohols with 6 to 16
carbon atoms in the chain, which has been abbreviated in previous documents as aliphatic
alcohols (Cx-Cxx) or (C6-C16). Currently, case 4004 consists of four active ingredients. Three
of these active ingredients are used as plant growth regulators on tobacco. These are described
as fatty alcohol blend (PC code 079029), 1-octanol (079037) and 1-decanol (079038). The fatty
alcohol blend under PC code 079029 is predominantly a mixture of 1-octanol and 1-decanol,
although some labels list 0.5% 1-hexanol (C6) and 1.5 % dodecanol (C12) among the active
ingredients. The single product listed under PC code 079037, although listed as 1-octanol, is
also in fact a mixture of 1-octanol and 1-decanol. The earliest registered label for use of
aliphatic alcohols for tobacco sucker control included in the Agency's Pesticide Product Label
System (PPLS) was issued to Uniroyal in 1964.
The fourth active ingredient in case 4004, 1-dodecanol (PC code 001509), was first
registered for use as a Lepidopteran pheromone/sex attractant in 1993. The potential human
health risks from 1-dodecanol were reassessed in 2002 by the Agency's Biopesticides and
Pollution Prevention Division (BPPD), as described in the document, Tolerance Reassessment
Decision Regarding Tolerance Exemption for the Biochemical Lepidopteran Pheromones. July
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26, 2002. This RED document describes the potential ecological effects of the use of 1-
dodecanol.
Other aliphatic alcohols are not assessed in this document. The fatty alcohol product
included under PC code 079059 is not being supported, and will be voluntarily cancelled. In
April 1995, the Agency completed a Reregi strati on Eligibility Decision (RED) for case number
4003 (Cl - C5), which consists of aliphatic alcohols with only one to five carbons. The active
ingredients addressed in that assessment included ethanol (PC code 001501), and isopropanol
(PC code 047501).
B.
Chemical Identification
The aliphatic alcohols are considered primary alcohols (i.e., the -OH group in the C-l
position). The aliphatic alcohols 1-octanol (PC code 079037) and 1-decanol (PC code 079038)
are also known by many other common names, and the fatty alcohol blend (PC code 079029) is a
generic term meaning that the compound is obtained by the hydrolysis of fatty acid esters. The
registrations under the name fatty alcohol blend (PC code 079029) are considered a mixture of
the linear, straight chain chemicals 1-octanol and 1-decanol. Tables 1-3 provide the chemical
identification for 1-octanol, 1-decanol, and 1-dodecanol, respectively.
Table 1. Chemical Identification of 1-Octanol
Type of Information
IUPAC Name
CAS Reg. No.
Other Names
Empirical Formula
Molecular Weight Number
of Carbons
Chemical Structure
Information for this Chemical
1-Octanol
111-87-5
Octyl alcohol; n-Octan-1-ol; n-Octanol; n-Octyl alcohol; Caprylic alcohol; Heptyl
carbinol; Octanol; Alcohol C-8; Capryl alcohol; n-Heptyl carbinol; Octan-1-ol; Prim-
n-octyl alcohol; Octanol-(l); Octyl alcohol, normal-primary; Primary octyl alcohol;
Hydroxyoctane
C8H180
130.23
The number of carbons is 8
^^^^^«'
Table 2. Chemical Identification of 1-Decanol
Type of Information
IUPAC Name
CAS Reg. No.
Other Names
Empirical Formula
Molecular Weight Number of
Carbons
Information for this Chemical
1-Decanol
112-30-1
Decyl alcohol; n-Decan-1-ol; n-Decanol; n-Decyl alcohol; Alcohol CIO;
Caprinic alcohol; Decanol; Nonylcarbinol; Decylic Alcohol; Decan-1-ol;
n- alcohol 22; Primary decyl alcohol; Nonyl carbinol
Capric alcohol;
Decanol-(l); Decyl,
C10H220
158.28
The number of carbons is 10
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Type of Information
Chemical Structure
Information for this Chemical
_^ _^ _^ _^ fl^J
Table 3. Chemical Identification of 1-Dodecanol
Type of Information
IUPAC Name
CAS Reg. No.
Other Names
Empirical Formula
Molecular Weight
Number of Carbons
Chemical Structure
Information for this Chemical
1-Dodecanol
112-53-8
Dodecyl alcohol; w-Dodecan-1-ol; w-Dodecyl alcohol; Alcohol C-12; Dodecanol-1; Laurie
Alcohol; Laurinic alcohol; Lauryl alcohol; 1 -Dodecyl alcohol; Duodecyl alcohol; w-Lauryl
alcohol; w-Lauric alcohol, primary; Dodecanol; 1-Hydroxydodecane; Hydroxydodecane
C8H180
186.33
The number of carbons is 12
HO
The aliphatic alcohols 1-octanol and 1-decanol are applied as water-based sprays to
hurley, flue cured and dark tobacco by hand using a back pack sprayer, or to tobacco plants by a
boom. The aliphatic alcohols are applied to tobacco at the button or early flower stage and act as
chemical pinching agents to control sucker shoots. The aliphatic alcohols dissolve the layer of
waxy cuticle on the plant, causing dehydration of the young sucker. Because these aliphatic
alcohols are applied solely on tobacco, its use is limited to the tobacco growing states, mainly on
the east coast (Connecticut, Pennsylvania, Virginia, North Carolina, South Carolina, Georgia,
and Florida), but also in Kentucky and Tennessee. Between 1.5 and 2 million pounds of
aliphatic alcohols are applied annually.
Recommended application rates range from approximately 8.5 Ibs ai/acre up to
approximately 21 Ibs active ingredient/acre, at 1 to 3 applications per year. However, 1-octanol
and 1-decanol have estimated volatilization half-lives of 3.5 and 1.0 minutes, respectively.
Therefore, the amount of the aliphatic alcohol available for runoff or for chronic exposure to
terrestrial animals is likely to be lower than the maximum label rates. As described below, the
ecological risk assessment took this into account when estimating potential exposure.
The volatility of 1-dodecanol is essential to its use as a pheromone in apple and pear
orchards. The pheromone is applied from polyethylene dispenser tubes hung throughout the
orchard. The active ingredient, 1-dodecanol (lauryl alcohols; PC code 001509), disperses
passively from the tube into the atmosphere over 3-4 months. Once dispersed from its dispensers,
1-dodecanol degrades quickly by photolysis in the air.
The aliphatic alcohols are used in, or can be naturally found in various food items. The
Food and Drug Administration permits the use of aliphatic alcohols as a food additive, under
certain conditions. The aliphatic alcohols have been found to be natural components of apples
and oranges, and have been reported as a component of edible seeds, oils and fermented
beverages.
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III. Summary of Aliphatic Alcohols Risk Assessments
The purpose of this summary is to assist the reader by identifying the key features and
findings of these risk assessments, and to help the reader better understand the conclusions
reached in the assessments. The human health and ecological risk assessment documents, and
supporting information listed in Appendix C were used to formulate the safety finding and
regulatory decision for aliphatic alcohols.
While the following risk assessments and related addenda are not included in this
document, they are available from the OPP Public Docket, docket number EPA-HQ-OPP-2007-
0134, and may also be accessed through the website http://www.regulations.gov/. Hard copies of
these documents may be found in the OPP public docket under this same docket number.
• Tolerance Reassessment Decision Regarding Tolerance Exemption for the Biochemical
Lepidopteran Pheromones. July 26, 2002;
• Human Health Risk Assessment: Aliphatic Alcohols: Human Health Chapter of the
Reregistration Eligibility Decision (RED) Document. Reregistration Case Number 4004.
June 30, 2006;
• Ecological Risk Assessment: Reregistration Eligibility Decision, Reregistration Case 4004:
Aliphatic Alcohols C-8, C-10 and C-12. September 8, 2006.
• Aliphatic Alcohols (1-octanol; 1-decanol): Tier 2 Aquatic Exposure Model (PRZMand
EXAMS) Estimates and Risk Characterization. November 28, 2006;
• Aliphatic Alcohols (1-octanol; 1-decanol): Addendum to PRZM and EXAMS refinement of
environmental concentrations in surface water (DPBarcode D334066; 11/28/2006).
Recalculation ofEECs considering volatilization from soil as a dissipation route;
Recalculation of Risk Quotients. December 11, 2006;
• Aliphatic Alcohols (1-octanol; 1-decanol) Addendum to Ecological Risk Assessment in
Support of RED: Reconsideration of Ecological Toxicity Data Gaps in Light of Surface
Water EEC Refinements. February 9, 2007.
A. Human Health Risk Assessment
The Agency has conducted a risk assessment of the tobacco plant growth inhibitor use of
the aliphatic alcohols. The Agency's screening level assessment was conducted using data
submitted by the registrants and published in the open literature. A summary of the Agency's
human health risk assessment is presented below. More detailed information associated with the
risks posed by the tobacco plant growth inhibitor use of the aliphatic alcohols can be found in the
human health risk assessment, Aliphatic Alcohols: Human Health Chapter of the Reregistration
Eligibility Decision (RED) Document. Reregistration Case Number 4004, which is available in
the public docket.
The potential human health risks from 1-dodecanol were assessed in 2002 by the
Agency's Biopesticides and Pollution Prevention Division (BPPD), as described in the document,
Tolerance Reassessment Decision Regarding Tolerance Exemption for the Biochemical
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Lepidopteran Pheromones. July 26, 2002. The tolerance exemption for Lepidopteran
pheromones, including 1-dodecanol, was determined to be in compliance with FQPA.
Toxicity Summary for Aliphatic Alcohols
The data base of submitted toxicity studies and published literature is sufficient to assess
the uses of the aliphatic alcohols. The available toxicity data base for the aliphatic alcohols
consists of acute toxicity, irritation, and sensitization studies. In addition, there are
developmental rat (oral and inhalation) toxicity studies and a 90-day rat (dermal) study. The
available mutagenicity studies include the Ames, micronucleus, and gene mutation assays.
Currently, there is no known mode of toxicological action for the aliphatic alcohols.
Based on the low hazard concern via the oral, dermal, and inhalation routes of exposure, a
quantitative risk assessment for the aliphatic alcohols is not appropriate. Therefore, the Agency
conducted a qualitative assessment.
Toxicity Profile
Available acute toxicity studies indicate the aliphatic alcohols are of low oral and dermal
toxicity. Acute inhalation studies with the rat resulted in estimates of the median lethal dose
(LDso) above the limit concentration of 2 mg/L. However, eye irritation studies resulted in
severe and sometimes non-reversible eye irritation. Dermal irritation studies revealed slight to
moderate irritation in rabbits, and the aliphatic alcohols generally did not produce sensitization in
tests with guinea pigs.
There are few subchronic or chronic toxicity data available for the aliphatic alcohols;
however, the available developmental toxicity studies revealed no adverse effects in fetal and
maternal parameters. The available genotoxicity and mutagenicity studies were negative. There
is currently no long-term rodent toxicity information regarding the carcinogenic potential for the
aliphatic alcohols. While neurotoxicity information is currently not available, there were no
clinical signs in any of the acute, subchronic, or developmental toxicity studies to suggest the
aliphatic alcohols elicit a neurotoxic effect. Based on the available data, there is no evidence that
warrants determining any dietary, oral, dermal, or inhalation endpoints to quantify sub-chronic or
chronic toxicity.
Finally, there is no evidence to suggest that the aliphatic alcohols cause increased
susceptibility in infants and children. Therefore, based on the results of the available studies, no
endpoints of toxicological concern have been identified for human health risk assessment
purposes. Table 4 summarizes the available toxicity data for the aliphatic alcohols.
Table 4. Acute Toxicity Data for the Aliphatic Alcohols
Guideline
No.
870.1100
81-1
Study Type
Acute oral [rat]
PC Code
079038
1-Decanol
MRID
44460401
46004601
Results
LD50 > 2000 mg/kg (other
studies report no deaths at 2000
mg/kg, one study showed LD50
Toxicity
Category
III
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Guideline
No.
870.1200
81-2
870.1300
81-3
870.2400
81-4
870.2400
81-4
870.2500
81-5
870.2600
81-6
870.2600
81-6
Study Type
Acute dermal [rat]
Acute inhalation
Tratl
[icii]
Acute eye irritation
[rabbit]
Acute eye irritation
[rabbit]
Acute dermal
irritation [rabbit]
Skin sensitization
[guinea pig]
Skin sensitization
[guinea pig]
PC Code
079038
1-Decanol
079038
1-Decanol
079038
1-Decanol
079029
Fatty
Alcohols
079038
1-Decanol
079038
1-Decanol
079029
Fatty
Alcohols
MRID
45507901
0060309
0064859
44460402
46004602
45507902
44460403
46004603
45517901
44460404
44578801
46004604
45517902
44340701
44407601
44460405
46004605
45517903
44407602
44460406
46004606
45507903
43386201
Results
=5000 mg/kg)
LD50 reported as > 2000 mg/kg;
(other studies reported LD50>
4000 mg/kg and one study
showed LD50 = 5000 mg/kg
LD50> 3.35 mg/L (other studies
showed LD50>5.07 mg/L and
LD50>7.08 mg/L)
Most severe effect reported as
cornea! opacity in all treated eye
at 7 days. Conjunctive irritation
until 7 and 14 days. Irreversible
vascularisation in one eye until
day 21
All 6 rabbits showed moderate to
severe irritation. Opacity up to 7
days. Slight iritis with
conjunctival redness to day 6,
slight chemosis to day 7 and
slight to severe discharge to day
8.
In one study, erythema, eschar
formation and edema was
evident at 72 hrs.
Test substance reported as mild
irritant.
Three studies reported 1-decanol
is not a skin sensitizer.
All animals survived. No
adverse effect on body weight.
Not a dermal sensitizer.
Toxicity
Category
III
IV
I-III
II-III
III-IV
NA
NA
B.
Environmental Risk Assessment
The Agency has conducted a screening-level risk assessment of the tobacco plant growth
inhibitor and pheromone uses of the aliphatic alcohols. The Agency's screening level
assessment was conducted using data submitted by the registrants in conjunction with acceptable
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ecotoxicity data from the open literature. Anticipated exposure pathways to non-target species
include oral exposure, and inhalation of aliphatic alcohol products.
A summary of the Agency's ecological risk assessment is presented below. More
detailed information associated with the ecological risks posed by use of the aliphatic alcohols
can be found in the environmental risk assessment, Reregistration Eligibility Decision for the
Aliphatic Alcohols, dated September 8, 2006, which is available in the public docket.
1. Environmental Fate and Transport
Because environmental fate data are not available, physical and chemical properties for
the aliphatic alcohols were estimated by Quantitative Structure-Activity Relationships (QSAR)
using EPISuite v3.21 (Estimation Programs Interface for Windows (EPIWIN)). The estimated
properties of 1-octanol, 1-decanol and 1-dodecanol differ somewhat, due to the different lengths
(i.e. number of carbons) in their straight, saturated carbon chains. As suggested by their
common names, 1-octanol has 8 carbons in its chain, 1-decanol has 10 carbons, and 1-dodecanol
has 12 carbons.
In spite of these small differences, the expected behavior of these aliphatic alcohols in the
environment is generally similar. The major route of dissipation in the field for these chemicals
is likely to be volatilization. The volatility half-lives for 1-octanol and 1-decanol were estimated
using the Dow Method described in the Handbook of Chemical Property Estimation Methods by
Lyman, Reehl and Rosenblatt. The half-lives for volatility from soil for 1-octanol and 1-decanol
were estimated to be 3.5 minutes and 1 minute, respectively. 1-dodecanol would likely volatilize
even more quickly, but the half-life was not estimated, since volatility from pheromone traps is
the known route of dissipation.
There is some uncertainty about the rate of volatility of 1-octanol and 1-decanol from
plant surfaces, since aliphatic alcohols are hydrophobic and, therefore, have affinity for the waxy
surfaces of plants. However, these volatility half-lives suggest that the aliphatic alcohols will not
be available long to expose non-target terrestrial animals, nor to be transported to surface water
bodies in runoff. Residues of 1-dodecanol are not expected on plants or in soil, since they are
dispersed in the air from pheromone traps, and then degraded by photolysis. The ecological risk
assessment concluded that except for terrestrial insects, which are the target for the pheromone
use of 1-dodecanol, "environmental exposures resulting from this use are likely negligible." The
risk assessment for this use was therefore qualitative.
Additional estimation of environmental fate parameters obtained from EPISuite provides
a basic set of data to perform a screening-level environmental risk assessment. The model
indicates that aliphatic alcohols have a moderate tendency to bind to soils. The portion of
applied chemical that binds to the soil, rather than volatilizing, will be subject to biodegradation,
with estimated half-lives for 1-octanol and 1-decanol of 2.3 days. The portion of applied
chemical that does volatilize is estimated to degrade in the air by reaction with hydroxyl radicals
with half-lives of about 10 hours.
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As mentioned above, dissipation via volatilization will greatly reduce the amount of
aliphatic alcohols reaching surface-water bodies, and aliphatic alcohols will volatilize from water
as well as soil. However, the fraction that does reach surface water will not be degraded by
hydrolysis. These alcohols have the potential to bioaccumulate in fish, but the rates of uptake,
metabolism, and depuration, as well as the nature of metabolites, are not known. However, the
magnitude of the bioconcentration factors (BCF) suggests a low potential to bioconcentrate.
EPISuite does not provide information on the rates of formation/decline of product, the
nature and relative amounts of transformation products, and their distribution in soil/sediment-
water-air. Therefore, the specific nature and persistence of potential biotransformation products
(primary biodegradation) are not known. However, the ultimate biotransformation products of
the aliphatic alcohols are water and carbon dioxide.
2. Ecological Risk Assessment
The Agency uses a pesticide's use profile, exposure data, and toxicity information to
determine risk estimates to non-target terrestrial and aquatic organisms. Estimated
environmental concentrations (EECs) are used to calculate risk quotients (RQs). EECs are based
on the maximum application rate(s) which would potentially yield the greatest exposure. An RQ
is derived by dividing the EEC by a single estimate of toxicity. The Agency then compares an
RQ to its Level of Concern (LOG) to determine if exposure to the aliphatic alcohols could
potentially pose a risk to non-target organisms (RQs that exceed the LOG indicate potential risk).
Table 5 outlines LOCs, and the Agency's corresponding risk presumptions.
Table 5. Agency Level of Concerns and Risk Presumptions
Risk Presumption
Acute Risk - there is a potential for
acute risk
Acute Endangered Species -
endangered species may be adversely
affected
Chronic Risk - there is potential for
chronic risk
LOC Terrestrial
Animals
0.5
0.1
1
LOC Aquatic
Animals
0.5
0.05
1
LOC Plants
1
1
N/A
a. Exposure to Aquatic Organisms
The Agency ran a number of exposure modeling simulations to derive expected
environmental concentrations of aliphatic alcohols in surface water. The Agency first ran the
Tier I GENEEC model, which resulted in exceedences of the endangered species level of
concern (LOC) for freshwater fish and estuarine/marine invertebrates for some application
scenarios. However, these simulations did not consider the volatilization of aliphatic alcohols
from soil, and each thereby overestimated potential exposure.
Although GENEEC is not designed to consider volatility from soil directly, the Agency
used an indirect method to consider volatility with the GENEEC model and to refine the aquatic
exposure assessment. As described above, the volatility half-lives for the aliphatic alcohols were
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estimated using the Dow Method described in the Handbook of Chemical Property Estimation
Methods (Lyman, et al., 1982). The half-lives for volatility from soil for 1-octanol and 1-decanol
were estimated to be 3.5 minutes and 1 minute, respectively. Such short volatility half-lives
mean that little pesticide will remain by the time a runoff event occurred, unless rainfall began
immediately after application.
To simulate this scenario using GENEEC, the Agency determined the amount of 1-octanol
or 1-decanol that would remain in the field 3 to 4 minutes after application at the maximum rates
allowed on the label. GENEEC was then run in the standard fashion, but with this "effective
application rate." Even though this was done using estimated volatility half-lives on the order of
a couple of minutes, the resulting EECs are still considered upper-bound. GENEEC does not
simulate a rainfall event until two days after application; if rainfall does not occur until two days
after actual application of 1-octanol or 1-decanol, there could be very little product remaining to
be subject to transport in runoff. For this reason, the simulations considered only a single
application, although aliphatic alcohols can be used more than once within a single growing
season.
b. Toxicity to Aquatic Organisms
Registrant-submitted data and open literature studies suggest that the aliphatic alcohols
are "slightly" to "moderately" toxic to freshwater fish. Although the data base is not complete
for all compounds in the aliphatic alcohol registration case, there are adequate data to assess the
acute risk to freshwater fish. Although there are no registrant-submitted acute toxicity data
available for estuarine/marine fish, data from the open literature provided the information to
assess the acute risks of aliphatic alcohols to these organisms. The relevant study from the open
literature indicates that 1-octanol is "slightly" toxic, and 1-decanol is "moderately" toxic to
estuarine/marine fish.
No chronic toxicity guideline studies exist for any of the aliphatic alcohols. However,
chronic data for freshwater fish from the open literature on 1-octanol provide an endpoint which
the Agency used to calculate RQs. Chronic toxicity data for aquatic invertebrates on the
aliphatic alcohols were also drawn from the open literature. The Agency used a chronic no
observed adverse effect concentration (NOAEC) of 1 mg/L for reproductive effects for 1-octanol.
The Agency notes that chronic toxicity data on 1-decanol for aquatic invertebrates would reduce
the uncertainty posed by the lack of these data. A summary of all toxicity endpoints is presented
below in Table 6.
Table 6. Toxicity Reference Values Used to Calculate RQs for Aliphatic Alcohols
Taxonomic
Group
Freshwater Fish
Assessment
Endpoint
Survival
Reproduction,
Growth
1-Octanol
Species/
Toxicity Endpoint
Fathead minnow
Acute LC50 = 12.2 mg/L
Fathead minnow
NOAEC = 0.75 mg/L
1-Decanol
Species/
Toxicity Endpoint
Fathead minnow
Acute LC50 = 2.3 mg/L
No data available
-------
Taxonomic
Group
Freshwater
Invertebrates
Estuarine/marine
Fish
Estuarine/marine
Invertebrates
Aquatic Plants
Assessment
Endpoint
Survival
Reproduction,
Growth
Survival
Reproduction,
Growth
Survival
Reproduction,
Growth
Survival,
Growth
1-Octanol
Species/
Toxicity Endpoint
Water flea
AcuteEC50 = 4.16mg/L
Water flea
Chronic NOAEC = 1 mg/L
Bleak
LC50 = 15 mg/L
No data available
Harpacticoid copepod
LC50 = 58 mg/L
No data available
Scenedesmus subspicatus
EC50 = 6.5 mg/L; EC10 =2.8 mg/L
1-Decanol
Species/
Toxicity Endpoint
Water flea
Acute EC50 =6.5 mg/L
No data available
Bleak
LC50 = 7.2 mg/L
No data available
Harpacticoid copepod
LC50 = 4 mg/L
No data available
No data available
LC50. Median Lethal Concentration, statistically derived single concentration that can be expected to cause death in
50% of the test animals; EC50. Median Effect Concentration, statistically derived single concentration that can be
expected to cause an adverse effect in 50% of the test animals or plants; ECio- statistically derived single
concentration that can be expected to cause an adverse effect in 10% of the test animals or plants; NOAEC - no
observed adverse effect concentration.
c. Risk to Aquatic Organisms
Based on the refined surface water EECs and the available ecotoxicity data for 1-octanol
and 1-decanol, RQs for aquatic animals do not exceed acute LOCs. In addition, although chronic
toxicity data are available for 1-octanol, but not 1-decanol, aliphatic alcohols do not appear to
pose a chronic risk to freshwater aquatic animals. No chronic toxicity data are available for
estuarine/marine fish and invertebrates. In spite of these data gaps, the Agency does not
anticipate chronic risk to estuarine marine fish and invertebrates. As described above, little 1-
octanol or 1-decanol would likely be available for transport in runoff if a significant rain event
did not occur within a few hours of application. Estimated RQs for 1-decanol and 1-octanol are
summarized in Tables 7-10 below.
Table 7. Acute and Chronic RQs for Freshwater Fish
Chemical
1-Decanol
1-Octanol
Effective Application
Rate (Ibs a.i./acre)
1.95, 1 application
4.4, 1 application
Peak
EEC
(Mg/ )
57
140
Toxicity Value
LC50 ~ 2300
NOAEC -nd
LC50 ~ 12200
NOAEC = 750
Acute
RQ
0.02
0.01
60-Max
Average
EEC
(Hg/L)
13
29
Chronic RQ
nd
-------
Table 8. Acute and Chronic RQs for Estuarine/Marine Fish
Chemical
1-Decanol
1-Octanol
Effective Application
Rate (Ibs a.i./acre)
1.95, 1 application
4.4, 1 application
Peak
EEC
(PW )
57
140
Toxicity Value
LC50 ~ 7200
NOAEC - nd
LC50 ~ 15000
NOAEC -nd
Acute
RQ
<0.01
<0.01
60-Max
Average
EEC
(Hg/L)
13
29
Chronic RQ
nd
nd
Table 9. Acute and Chronic RQs for Freshwater Invertebrates
Chemical
1-Decanol
1-Octanol
Effective Application
Rate (Ibs a.i./acre)
1.95, 1 application
4.4, 1 application
Peak
EEC
(Mg/ )
57
140
Toxicity Value
Oig/L)
EC™ - 6500
NOAEC - nd
EC™ - 4160
NOAEC = 1000
Acute
RQ
O.01
0.03
21-Max
Average
EEC
(ng/L)
29
70
Chronic RQ
nd
-------
d. Exposure, Toxicity and Risk to Terrestrial Organisms
Birds
Available toxicity data indicate that the aliphatic alcohols are categorized as "practically
non-toxic" to birds on acute oral and dietary bases. Acute risks to birds were not quantified,
because no discreet median lethal doses or concentrations were established in the acute oral and
dietary studies. An acute dietary study from the open literature reported a dietary LCso for
bantam chickens of 201,000 ppm (100% 1-decanol). This level is more than 20 times greater
than the highest predicted dietary exposure level (-10,000 ppm). Therefore, the Agency
concludes that the aliphatic alcohols do not pose an acute risk to birds.
No avian chronic toxicity studies were available for any of the aliphatic alcohols and,
therefore, the Agency cannot directly assess the potential chronic risk to avian species. However,
since 1) the aliphatic alcohols are not acutely toxic to birds at doses many times higher than
expected exposure, 2) the volatility of the aliphatic alcohols makes chronic exposure unlikely,
with EECs dropping more than an order of magnitude within 30 minutes, 3) the aliphatic
alcohols assessed are listed as food additives and are "Generally Recognized as Safe" (GRAS)
by the U.S. Food and Drug Administration1, and 4) a mammalian chronic toxicity study indicates
the aliphatic alcohols are not chronically toxic to mammals, the Agency does not expect a
chronic risk to birds, and will not require chronic avian toxicity studies at this time.
Mammals
Acute oral mammalian toxicity data indicate that the aliphatic alcohols are "practically
non-toxic" to mammals on an acute oral basis. Four studies performed with laboratory rats did
not result in LCso endpoints with which RQs could be calculated. The Agency concludes that
aliphatic alcohols do not pose an acute dietary risk to mammals.
In the single chronic mammalian developmental toxicity study, which used a 1-
decanol/1-octanol blend, no chronic effects were observed in laboratory rats, even at the
maximum tested dose of 957 mg/kg bw/day. It is unknown if the predicted exposures approach
the level at which effects may occur since no LOAEC was identified in the chronic study.
However, the Agency does not anticipate chronic risk to mammals, considering the volatility of
the aliphatic alcohols, and the acceptance of these chemicals as food additives, as described
above.
Terrestrial Insects
Available toxicity data indicate that aliphatic alcohols are "practically non-toxic" to
honey bees (acute contact LDso > 25 jig/bee). However, given that aliphatic alcohols can be
used as Lepidopteran sex inhibitors, there is a potential for sublethal (e.g., reproductive) effects
on non-target Lepidopterans, such as butterflies. This potential effect cannot be quantified at this
time.
1 http://vm.cfsan.fda.gov/~dms/eafus.html
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Terrestrial Plants
Tier-I terrestrial plant seedling emergence study data suggest a fatty alcohol blend (1-
decanol and 1-octanol) is not toxic to most plants at the maximum rate tested (18.03 Ibs ai/A).
An EC25 could not be established for tested species, although lesser effects were observed in
cucumbers, carrots and tomatoes. Therefore, the Agency did not calculate RQs based on
seedling emergence effects.
EC25 values and related no-effect levels were established for two (corn and cucumber) of
10 crop plants tested in a submitted vegetative vigor study. The Agency used these endpoints in
the TerrPlant model to calculate RQs (Table 12). All were below the Agency's LOG of 1.
Table 12. Terrestrial Plant Vegetative Vigor RQs from Drift only for Terrestrial Plants"
Class of Terrestrial Plant
Non-endangered species
Endangered species
Monocot
0.02
0.19
* Based on vegetative vigor monocot NOAEL = 1. 12
Ibs a.i./A, EC25 = 14.8 Ibs a.i./A (MRIDs 42514701,
Dicot
0.01
0.36
Ibs a.i./A, EC25 = 9.02 Ibs a.i./A; dicot NOAEL
43379602)
= 0.58
e. Adverse Ecological Incidents
There are currently no adverse ecological incidents listed in the Ecological Incident
Information System (EIIS) that are associated with the aliphatic alcohols.
f. Endangered Species
Based upon the screening-level assessment conducted on aliphatic alcohols, the Agency
has not definitively identified exceedences of endangered species LOCs for direct effects to non-
target animals or plants. Acute RQs did not exceed endangered species LOCs for birds,
mammals, terrestrial plants, freshwater fish and invertebrates, or estuarine/marine fish and
invertebrates. Chronic data were not available for birds and estuarine/marine fish and
invertebrates. As described above, the Agency believes that the volatility and low toxicity in
available acute and chronic toxicity studies for mammals and freshwater animals suggest that
chronic risk to birds and estuarine/marine animals is unlikely. However, because the toxicity
data are not available, the Agency cannot completely preclude risk to listed birds and
estuarine/marine animals at this time. Similarly, since a no-effect level was not determined for
aquatic plants, the Agency cannot preclude direct effects on these organisms, although exposure
is expected to be negligible.
The Agency considers a potential for not only direct effects, but also adverse indirect
effects to listed species that rely on other affected organisms. Because direct effects to aquatic
plants cannot be precluded, indirect effects to listed aquatic species which rely on aquatic plants
can also not be dismissed. Similarly, indirect effects to terrestrial plants and animals cannot be
precluded because of potential reproductive effects of aliphatic alcohols to some terrestrial
insects.
13
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Table 13. Potential Listed Species Risks Associated with Direct or Indirect Effects Due to
Applications of Aliphatic Alcohols as Shoot Inhibitors on Tobacco.
Listed Taxon
Terrestrial and semi-aquatic plants -
monocots
Terrestrial and semi-aquatic plants -
dicots
Birds
Terrestrial-phase amphibians
Reptiles
Mammals
Aquatic non-vascular plants*
Aquatic vascular plants
Freshwater fish
Aquatic -phase amphibians
Freshwater crustaceans
Mollusks
Marine/estuarine fish
Marine/estuarine crustaceans
Direct Effects
Acute
No
No
No
No
No
No
Insufficient data
Insufficient data
No
No
No
No
No
No
Chronic
N/A
N/A
No data
No data
No data
No
N/A
N/A
No
No
No
N/A
No data
No data
Indirect Effects to Endangered
Species
Possible
Possible
Possible
Possible
Possible
Possible
N/A
N/A
Possible
Possible
Possible
Possible
Possible
Possible
' At the present time, no aquatic non-vascular plants are included in Federal listings of threatened and endangered species. The
taxonomic group is included here for the purposes of evaluating potential contributions to indirect effects to other taxa and as a
record of exceedences should future listings of non-vascular aquatic plants warrant additional evaluation of Federal actions.
Further analysis regarding the overlap of individual species with each use site is required
prior to determining the likelihood of potential impact to listed species. At the screening level,
this analysis is accomplished using the Location of Crops and Threatened and Endangered
Species (LOCATES) data base, which uses location information for listed species at the county
level and compares it to agricultural census data for crop production at the same county level of
resolution. The ecological risk assessment includes a complete listing of aquatic plants, birds,
reptiles, terrestrial-phase amphibians, mammals, and terrestrial invertebrates associated with the
States where the aliphatic alcohols are use as a plant growth regulator on tobacco.
IV. Risk Management, Reregistration, and Tolerance Reassessment Decision
A. Determination of Reregistration Eligibility
Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of
relevant data concerning an active ingredient, whether or not products containing the active
ingredient are eligible for reregi strati on. The Agency has previously identified and required the
submission of the generic (i.e., active ingredient-specific) data required to support reregi strati on
of products containing aliphatic alcohols as an active ingredient. The Agency has completed its
review of these generic data, and has determined that the data are sufficient to support
reregi strati on of all products containing aliphatic alcohols (C6 - C16).
The Agency has completed its assessment of the human health and ecological risks
associated with the use of pesticide products containing aliphatic alcohols (C6 - C16). The
Agency has determined that aliphatic alcohol-containing products are eligible for reregistration
provided that label amendments are made as outlined in Chapter V. Appendix A summarizes the
14
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uses of aliphatic alcohols (C6 - C16) that are eligible for reregi strati on. Appendix B identifies
the generic data requirements that the Agency reviewed as part of its determination of
reregi strati on eligibility of aliphatic alcohols (C6 - C16), and lists the submitted studies that the
Agency found acceptable.
The Agency has identified eye-irritation concerns that warrant specific label language
concerning personal protective equipment (PPE) and the length of restricted-entry intervals after
application for tobacco uses of the aliphatic alcohols (C6 - C16). If all changes outlined in this
document are incorporated into the product labels, the eye-irritation concerns will have been
mitigated. Should a registrant fail to implement any of the reregi strati on requirements identified
in this document, the Agency may take regulatory action to address these concerns.
B. Public Comment Period
Because the risks associated with the use of aliphatic alcohols were low and did not
warrant mitigation measures, a Phase 3 public comment period on the aliphatic alcohols risk
assessments was not conducted. However, a 60-day public comment period will be conducted
after the RED is issued, and will be announced in the Federal Register. Comments may be
submitted under Docket number EPA-HQ-OPP-2007-0134 at http://www.regulations.gov/. The
RED document and technical supporting documents for aliphatic alcohols are also available to
the public under docket identification (ID) number EPA-HQ-OPP-2007-0134. In addition, the
aliphatic alcohols RED document may be downloaded or viewed through the Agency's website
at http://www.epa.gov/pesticides/reregistration/status.htm.
C. Regulatory Position
1. Regulatory Rationale
The Agency has determined that aliphatic alcohols-containing products are eligible for
reregi strati on provided that specified label amendments are made. The following is a summary
of the rationale for managing risks associated with the use of aliphatic alcohols.
a. Human Health Risk Management
There are no human health risk concerns for the aliphatic alcohols with the exception of
eye irritation for 1-decanol. 1-decanol, which is a component of all active tobacco use
formulations of the aliphatic alcohols (C6 - C16), is an acute toxicity category I eye irritant and,
therefore, pursuant to the Worker Protection Standards (WPS), products with agricultural uses
must require a 48 hour REI and the following PPE for early entry: coveralls, chemical-resistant
gloves made of any water proof material, shoes plus socks, and protective eyewear.
b. Ecological Risk Management
The risk assessment identified no exposure scenarios with aliphatic alcohols that pose
ecological risks of concern to the Agency, including direct effects on endangered species. Thus,
15
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no mitigation measures to address ecological risks are necessary for the reregi strati on of aliphatic
alcohols.
Moreover, because of the low risks associated with the use of aliphatic alcohols, as
summarized in this document, the Agency concludes that spray drift mitigation is not needed as
part of the reregi strati on eligibility determination.
2. Endocrine Disrupter Effects
Following recommendations of its Endocrine Disrupter Screening and Testing Advisory
Committee (EDSTAC), EPA determined that there was a scientific basis for including, as part of
the program, the androgen and thyroid hormone systems, in addition to the estrogen hormone
system. EPA also adopted EDSTAC's recommendation that EPA include evaluations of
potential effects in wildlife. For pesticides, EPA will use FIFRA and, to the extent that effects in
wildlife may help determine whether a substance may have an effect in humans, FFDCA
authority to require the wildlife evaluations. As the science develops and resources allow,
screening of additional hormone systems may be added to the Endocrine Disrupter Screening
Program (EDSP).
When the appropriate screening and/or testing protocols being considered under the
EDSP have been developed, individual pesticides may be subject to additional screening and/or
testing. However, in the available toxicity studies for the aliphatic alcohols, there was no
evidence of endocrine disruption.
3. Endangered Species
The Endangered Species Act required federal agencies to ensure that their actions are not
likely to jeopardize listed species or adversely modify designated critical habitat. The Agency
has developed the Endangered Species Protection Program to identify pesticides whose use may
cause adverse impacts on federally listed endangered and threatened species, and to implement
mitigation measures that address these impacts. To assess the potential of registered pesticide
uses that may affect any particular species, EPA puts basic toxicity and exposure data developed
for the REDs into context for individual listed species and considers ecological parameters,
pesticide use information, the geographic relationship between specific pesticide uses and
species locations and biological requirements and behavioral aspects of the particular species.
When conducted, these analyses take into consideration any regulatory changes recommended in
this RED being implemented at that time. A determination that there is a likelihood of potential
effects to a listed species may result in limitations on the use of the pesticide, other measures to
mitigate any potential effects, and/or consultations with the Fish and Wildlife Service or National
Marine Fisheries Service, as necessary. If the Agency determines use of aliphatic alcohols "may
affect" listed species or their designated critical habitat, EPA will employ the provisions in the
Services regulations (50 CFR Part 402).
The ecological assessment that EPA conducted for this RED does not, in itself, constitute
a determination as to whether specific species or critical habitat may be harmed by the pesticide.
Rather, this assessment serves as a screen to determine the need for any species specific
16
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assessment that will evaluate whether exposure may be at levels that could cause harm to
specific listed species and their critical habitat. That assessment refines the screening-level
assessment to take into account the geographic area of pesticide use in relation to the listed
species, the habits and habitat requirements of the listed species, etc. If the Agency's specific
assessments for aliphatic alcohols result in the need to modify use of the pesticide, any
geographically specific changes to the pesticide's registration will be implemented through the
process described in the Agency's Federal Register Notice (54 FR 27984) regarding
implementation of the Endangered Species Protection Program.
The Agency has reviewed data and other information for the aliphatic alcohols (C6 -
C16) and concludes that this plant growth regulator does not pose a risk of direct acute effects to
most species listed under the Endangered Species Act, because EPA's screening-level
assessment shows 'no effect' on listed species or their critical habitat (RQ values were below the
level of concern for endangered species). There is some uncertainty regarding acute risk to
aquatic plants, however. Although the volatility of 1-octanol and 1-decanol suggests that
exposure to aquatic plants would be negligible, a no-observed-adverse-effect-level could not be
established and, therefore, indirect effects to listed aquatic animals which depend on aquatic
plants could not be precluded. Similarly, the Agency believes that the volatility and low toxicity
in available acute and chronic toxicity studies for mammals and freshwater animals suggest that
chronic risk to birds and estuarine/marine animals is unlikely. However, because the toxicity
data are not available, the Agency cannot completely preclude risk to listed birds and
estuarine/marine animals at this time.
D. Labeling Requirements
In order to be eligible for reregi strati on, various use and safety information will be
included in the labeling of all end-use products containing aliphatic alcohols. For the specific
labeling statements, refer to Section V of this RED document.
V. What Registrants Need to Do
The Agency has determined that aliphatic alcohols (C6 - C16)-containing products are
eligible for reregi strati on provided that the required label amendments are made. The Agency
intends to issue Data Call-In (DCIs) Notices requiring product-specific data. Generally,
registrants will have 90 days from receipt of a DCI to complete and submit response forms or
request time extension and/or waiver requests with a full written justification. For product-
specific data, the registrant will have eight months to submit data. Below are the label
amendments that the Agency intends to require for aliphatic alcohols to be eligible for
reregi strati on.
17
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A. Manufacturing Use Products
1. Additional Generic Data Requirements
The generic data base supporting the reregi strati on of aliphatic alcohols for currently
registered uses has been reviewed and determined to be substantially complete. However, a few
data gaps remain, and these are listed below.
Product Chemistry
830.7050 UV/VIS Spectrum for Pure Active Ingredient (PAI)
830.7950 Vapor Pressure
2. Labeling for Manufacturing-Use Products
To ensure compliance with FIFRA, manufacturing-use product (MUP) labeling should be
revised to comply with all current EPA regulations, PR Notices, and applicable policies. The
MUP labeling should bear the labeling contained in Table 14.
B. End-Use Products
1. Additional Product-Specific Data Requirements
Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific
data regarding the pesticide after a determination of eligibility has been made. The Registrant
must review previous data submissions to ensure that they meet current EPA acceptance criteria
and if not, commit to conduct new studies. If a registrant believes that previously submitted data
meet current testing standards, then the study MRID numbers should be cited according to the
instructions in the Requirement Status and Registrants Response Form provided for each product.
The Agency intends to issue a separate product-specific data call-in (PDCI), outlining specific
data requirements. For any questions regarding the PDCI, please contact Karen Jones at 703-
308-8047.
2. Labeling for End-Use Products
To be eligible for reregi strati on, labeling changes are necessary to implement measures
outlined in Section IV above. Specific language to incorporate these changes is specified in
Table 15. Generally, conditions for the distribution and sale of products bearing old
labels/labeling will be established when the label changes are approved. However, specific
existing stocks time frames will be established case-by-case, depending on the number of
products involved, the number of label changes, and other factors.
18
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C. Labeling Changes Summary Table
In order to be eligible for reregi strati on, amend all product labels to comply with the
following table. Table 14 describes how language on the labels should be amended.
19
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Table 14: Labeling Changes Summary Table for 1-Octanol, 1-Decanol and Fatty Alcohols
Description
1-Octanol, 1-Decanol and Fatty Alcohols : Required Labeling Language
Placement on Label
Manufacturing-Use Products
Required on all
MUPs
"Only for formulation into a growth regulator for tobacco sucker control.'
Directions for Use
One of these
statements may
be added to a
label to allow
reformulation of
the product for a
specific use or all
additional uses
supported by a
formulator or
user group.
"This product may be used to formulate products for specific use(s) not listed on the MP label if the
formulator, user group, or grower has complied with U.S. EPA submission requirements regarding
support of such use(s)."
"This product may be used to formulate products for any additional use(s) not listed on the MP label
if the formulator, user group, or grower has complied with U.S. EPA submission requirements
regarding support of such use(s)."
Directions for Use
Environmental
Hazards
Statements
Required by the
RED and Agency
Label Policies
"Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or
other waters unless in accordance with the requirements of a National Pollution Discharge
Elimination System (NPDES) permit and the permitting authority has been notified in writing prior
to discharge. Do not discharge effluent containing this product to sewer systems without previously
notifying the local sewage treatment plant authority. For guidance contact your State Water Board
or Regional Office of the EPA."
Directions for Use
20
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End-Use Products Intended for Occupational Use (WPS and non-WPS)
Handler PPE
Requirements1 for (insert
type of formulation)
Note: Separate sections
should be used for each
formulation type (i.e.
liquids, powders,
granulars, etc...) unless
the required handler PPE
is identical for all
formulation types.
"Personal Protective Equipment (PPE)
Mixers, loaders, applicators, and other handlers must wear:
> Long-sleeved shirt and long pants and,
> Shoes plus socks"
Precautionary
Statements:
Hazards to
Humans and
Domestic
Animals
User Safety Requirements
"Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for
washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.
"Discard clothing and other absorbent material that have been drenched or heavily contaminated
with the product's concentrate. Do not reuse them."
Precautionary
Statements:
Hazards to
Humans and
Domestic
Animals
immediately
following the
PPE
requirements
User Safety
Recommendations
"USER SAFETY RECOMMENDATIONS"
"Users should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet.'
"Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly
and put on clean clothing."
"Users should remove PPE immediately after handling this product. Wash the outside of gloves
before removing. As soon as possible, wash thoroughly and change into clean clothing."
Precautionary
Statements
under:
Hazards to
Humans and
Domestic
Animals
immediately
following
Engineering
Controls
(Must be
placed in a
21
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Environmental
Hazards Statement
"ENVIRONMENTAL HAZARDS"
Do not apply directly to water, or to areas where surface water is present or to intertidal areas
below the mean high water mark. Do not contaminate water by cleaning of equipment or disposal
of wastes."
box.)
Precautionary
Statements
under
Environmental
Hazards
Restricted-Entry Interval
for products with WPS
uses
"Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of
48 hours."
Directions for
Use,
Agricultural
Use
Requirements
Box
Early Entry Personal
Protective Equipment for
products with WPS uses
"PPE required for early entry to treated areas that is permitted under the Worker Protection
Standard and that involves contact with anything that has been treated, such as soil or water, is:
> coveralls,
> shoes plus socks,
> chemical-resistant gloves made of any waterproof material,
> protective eyewear."
Directions for
Use,
Agricultural
Use
Requirements
Box
General Application
Restrictions for products
with WPS or non-WPS
uses on the label
"Do not apply this product in a way that will contact workers or other persons, either directly or
through drift."
"Only protected handlers may be in the area during application."
Place in the
Direction for
Use.
PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE in this document. In the case of multiple
active ingredients, the more protective PPE must be placed on the product labeling. For guidance on which PPE is considered more protective, see PR Notice 93-7.
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Appendix A
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