United States Environmental Protection Agency Office of Prevention, Pesticides and Toxic Substances (7505P) &EPA Pesticide Fact Sheet Name of Chemical: Mammalian Gonadotropin Releasing Hormone (GnRH) Reason for Issuance: New Chemical Nonfood Use Date Issued: September 2009 1. Description of Chemical Peptide Chain: pyroGlul -His2-Trp3- Ser4 -Tyr5- Gly6 -Leu7-Arg8- Pro9- G lylONH2 [GnRH] Common Name: Mammalian Gonadotropin Releasing Hormone (GnRH) EPA PC Code: 116800 Chemical Abstracts Service (CAS) Number: 9034-40-6 Chemical Class: Sterilant/Hormone Registration Status: New Chemical, nonfood use Pesticide Type: Mammalian Contraceptive U.S. Producer: U.S. Department of Agriculture, APHIS, Pocatello Supply Depot 23 8 East Dillon Street Pocatello, ID 83201 ------- 2. Use Pattern and Formulations Mode of Action Application Sites Methods of Application Application Rate: 3. Science Findings The active ingredient, Mammalian Gonadotropin Releasing Hormone (GnRH) is conjugated into a large protein that initiates an immune response in the animal with its own GnRH resulting in contraceptive effects for a minimum of one year. GonaCon will be used to control wild white-tailed deer Odocoileus virginianus) populations in areas where they have become a nuisance (e.g, urban and suburban settings). The vaccine will be administered to restrained female deer using preloaded syringes with an 18 or 19 gauge stainless steel hypodermic needle intramuscularly into a large muscle mass by hand injection only. GonaCon is classified as a Restricted Use Pesticide. Use is restricted to USDA APHIS Wildlife Services or state wildlife management personnel or persons working under their authority. Female deer are injected with a single injection containing 1.0 ml of GonaCon at least two to three months prior to the onset of rut for full contraceptive effect. If multi year contraceptive effects are desired, a second vaccination may be given 30 to 60 days after the first injection or during the following year. Two formulations (basic and alternate) are proposed for registration. Available data supporting the use and registration of Mammalian Gonadotropin Releasing Hormone including product chemistry, toxicology, efficacy, and ecological effects and environmental fate are summarized below. ------- Table 1. Product Chemistry Summary Peptide structure Common name CAS Reg. No. Color Physical State Melting Point Boiling Point Odor Stability to Normal and Elevated Temperatures, Metal, and Metal Ions Oxidation/Reduction Action pH Flammability Explodability Vapor pressure Water Solubility Storage stability Corrosion Characteristics , "ij^x.^ Ly f jif ' i vZ\>p' GB«S\EBi«9 \ ' / /\\\^ ) — V- A ftjsrs Mammalian Gonadotropin Releasing Hormone (GnRH) 9034-40-6 white Active: solid: powder EU: liquid: somewhat creamy in appearance N/A Waiver request Waiver request: Solid at room temperature. Active: odorless EU: odorless N/A Waiver request N/A Waiver request Active: NA EU: pH = 6.49 N/A Waiver request N/A Waiver request N/A Waiver request N/A Waiver request N/A product's shelf life will be ^6 months so not necessary N/A product's shelf life will be ^6 months so not necessary TOXICOLOGY SUMMARY The Registrant submitted the studies listed in Tables 2, which include a number of toxicity studies. The Registrant submitted waiver requests which were granted for acute inhalation and dermal sensitization. ------- Acute Toxicity Data GnRH Table 2. Acute Toxicity Guideline No. OPPTS 870.1100 OPPTS 870.1200 OPPTS 870.1300 OPPTS 870.2400 OPPTS 870.2500 OPPTS 870.2600 Study Type Acute Oral Rat Acute Dermal Rat Acute Inhalation Rat Primary Eye Irritation Rabbit Primary Skin Irritation Rabbit Dermal sensitization Toxicity Results Category* All test animals survived 1 mL exposure. IV All test animals survived 1 mL exposure. IV WAIVED No cornea! opacity or iritis was observed. 1 -hour post- instillation: 3/3 treated eyes exhibited conjunctival redness (score 1-2) and discharge (score 1). No "positive" grade irritation was noted at the 24- hour observation. Treated eyes were free of all eye irritation by 72 -hours. No edema was observed at any treated site. Very slight IV erythema (score 1) was noted at all 3/3 test sites within 1-hour post-pad removal. Irritation severity decreased thereafter. No irritation was noted at the 72 -hour observation. The PDII was 0.5. WAIVED • Toxicity Category IV = No precautions required Chronic toxicity data requirements were waived. There is no human exposure from use of GonaCon, therefore no toxicity endpoints were selected because of the very limited potential worker and dietary exposure. ECOLOGICAL EFFECTS Waivers were submitted to fulfill required ecological effects and environmental fate guideline studies for the registration of GonaCon because of the limited potential for environmental releases. Since the product is labeled only for injection to deer by hand and the substance is expected to be rapidly metabolized in treated animals, the limited ------- potential risks to non-target organisms resulting from the proposed registration of GonaCon are not expected to exceed the Agency's concern levels. The proposed registration of GonaCon is expected to have no effect on endangered or threatened species EFFICACY GonaCon is intended to render a vaccinated female white-tailed deer infertile for a minimum of one year following vaccination. The label claims that GonaCon will not affect existing pregnancies but should cause infertility of the vaccinated animal in subsequent years. If multi-year contraceptive effects are desired, a second vaccination may be given 30-60 days after the first injection or during the following year. The label claims that there is a chance that some vaccinated females will become permanently sterile. Product performance studies were conducted by APHIS's National Wildlife Research Center (NWRC) both in the field over a two year period and in a laboratory over multiple years to compare two different formulations. The field test, initiated in 2004 used two sites consisting of fenced federal land near Silver Spring, MD. Female deer in the vaccinated group were dosed with the labeled rate of the vaccine during July and August 2004. All deer were marked with ear tags and radio telemetry collars equipped with mortality sensors. Reproductive status was assessed in the summers of 2005 and 2006 with visual inspection of the udders for signs of lactation. Results showed 88% efficacy in the summer after vaccination with lactation evident in 3 of the 26 does vaccinated (12%). Of the control group, reproductive status was able to be determined in 13 of the 15 deer and lactation was evident in 11 of those 13 doe (85%). In the second summer after vaccination lactation was evident in 10 of the remaining 19 vaccinated deer (53%) equating to an efficacy rate of 47%. In the control group, 10 of the 10 remaining deer (100%) had reproductive success. The lab study results showed the alternate formulation to be more effective than the basic formulation. The alternate formulation had a 100% success rate (5/5 does remained contracepted for two years) compared to the basic formulation with a 60% success rate after two years (3/5 does contracepted). Due to economic and supply reasons however, it is necessary for the product to carry both formulations. 4. Summary of Regulatory Position and Rationale Available data provide adequate information to support the conditional registration of GnRH as an effective population control method for nuisance white-tailed deer. White-tailed deer have been classified by EPA as a public health pest because they are a host for deer ticks that may cause Lyme disease and they are a cause of vehicle accidents. ------- In many urban and suburban areas white-tailed deer populations have become over abundant and are considered a year-round nuisance causing many human-wildlife conflicts. Since these areas are typically non hunting areas, where building and population densities do not allow for safe shooting zones, local laws prohibit guns or shooting or public opinion does not support hunting, there has not been an economically feasible solution to control overabundant deer populations. In many of these urban and suburban areas, deer have been known to inflict significant economic damage to gardens and landscapes of homeowners associations, golf courses, private residential yards, etc. When deer are in numbers exceeding 20 per square mile, as they are becoming in many areas, they can inflict severe damage to resident flora and fauna. This can adversely affect the ecosystem and the wildlife that depend on that ecosystem. Since deer in these areas are so well fed, female deer, which normally give birth to twins may be becoming more fertile which is evident by an increase in triplet births. This, and the fact that deer in developed areas appear to be more nocturnal to avoid human contact, is contributing to rapidly increasing populations and problems. According to a 2006 study, the National Highway Traffic Safety Administration reported that there are about 1.5 million car accidents with deer resulting in over $1 billion of damage and 150 human fatalities annually. GnRH will not only help prevent increases in deer numbers through contraception, but should decrease the number of car accidents during the fall mating season - which is associated with a surge in car collisions with deer as bucks chase fertile does, sometimes for miles. Deer can also play a role in spreading disease as they are a main host for blacklegged ticks (Ixodes scapularis), more commonly known as deer ticks, which are a carrier of Lyme disease. There has been a sharp increase in cases of Lyme disease in suburban/urban areas with significant deer populations. Contraception of nuisance deer using GnRH is not intended to replace hunting (where it is an option) as a population control method. GnRH is intended to be used in combination with other population management techniques since it cannot alone reduce already over abundant populations. Since GnRH is a nonlethal alternative to population control, many animal rights groups enthusiastically support this registration. The registration of GonaCon has received letters of support from the Department of Natural Resources at Cornell University and White Buffalo, Inc. a non-profit wildlife organization based out of Connecticut. At Cornell University, deer have caused damages to plants in research and teaching plots as well as dozens of car accidents. Currently, the university attempts population management of deer by capturing and surgically sterilizing deer via tubal ligation. This method however is both time consuming and costly, with expenses of approximately $1,000 per deer along with the impracticality of finding surgery staff and anesthesiologists during the early and late hours that deer are typically captured. The use of GnRH is also supported by the Humane Society of the United States and the Wildlife Society as a humane and "necessary" method of deer population control. ------- GonaCon was mentioned in an April 2009 article in the Washington Post Magazine as a possible population control method for deer in Rock Creek Park in Washington, DC and suburban Maryland. 5. Labeling Restrictions To mitigate any risks, the following requirements have been imposed: • Restricted -Use Pesticide classification due to non-target injection hazard. • Application is restricted to USDA APHIS Wildlife Services or state wildlife management agency personnel or persons working under their authority only. • Administration of vaccine is only by hand injection to mitigate any non-target or environmental risks that occur with administration with darts. • Use restricted to only one species: white-tailed deer (Odocoileus virginianus). • PPE requirements include: long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. Children are not allowed in areas where product is used • A warning that pregnant women should not be involved in handling or injecting GonaCon and that all women should be aware that accidental self-injection may cause infertility. 6. Conditional Data Requirements Because of the unique chemical nature of GnRH additional preliminary analysis and certified limits data are necessary. The registrant must submit this data to the Agency upon completion. Conditional data required for GonaCon consists of: • Guideline 830.1700 Validating the method of analysis of the formulation and additional preliminary analysis • Guideline 830.1750 Certified Limits ------- Contact Person at USEPA Mailing address: Autumn Metzger Biologist, Insecticide-Rodenticide Branch Environmental Protection Agency Office of Pesticide Programs Registration Division (7505P) Insecticide Branch 1200 Pennsylvania Avenue NW Washington, D.C. 20460 Office location and telephone number: Room S-7224, One Potomac Yard 2777 S. Crystal Drive Arlington, VA 22202 703-305-5314 DISCLAIMER: The information in this Pesticide Fact Sheet is for information only and is not to be used to satisfy data requirements for pesticide registration. The information is believed to be accurate as of the date on the document. ------- APPENDIX I GLOSSARY OF TERMS AND ABBREVIATIONS ADNT Acute delayed neurotoxicity a.i. Active Ingredient aPAD Acute Population Adjusted Dose ARI Aggregate Risk Index BCF Bioconcentration Factor CAS Chemical Abstracts Service ChE Cholinesterase ChEI Cholinesterase inhibition cPAD Chronic Population Adjusted Dose %CT Percent crop treated DAT Days after treatment DEEM-FCID Dietary Exposure Evaluation Model - Food Consumption Intake Database DNA Deoxyribonucleic acid DNT Developmental neurotoxicity DIT Developmental immunotoxicity DWLOC Drinking Water Level of Comparison. EC Emulsifiable Concentrate Formulation EEC Estimated Environmental Concentration. The estimated pesticide concentration in an environment, such as a terrestrial ecosystem. EPA U.S. Environmental Protection Agency FQPA Food Quality Protection Act GLC Gas Liquid Chromatography GLN Guideline Number 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. 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. LOAEL Lowest Observed Adverse Effect Level LOAEC Lowest Observed Adverse Effect Concentration LOG Level of Concern LOD Limit of Detection LOQ Limit of Quantitation mg/kg/day Milligram Per Kilogram Per Day mg/L Milligrams Per Liter MOE Margin of Exposure ------- MRID Master Record Identification (number), EPA's system of recording and tracking studies submitted MTD Maximum tolerated dose NA Not Applicable NOEC No Observable Effect Concentration NOEL No Observed Effect Level NOAEL No Observed Adverse Effect Level NOAEC No Observed Adverse Effect Concentration NPDES National Pollutant Discharge Elimination System OP Organophosphate OPP EPA Office of Pesticide Programs OPPTS EPA Office of Prevention, Pesticides and Toxic Substances PAD Population Adjusted Dose PAG Pesticide Assessment Guideline PAM Pesticide Analytical Method PHED Pesticide Handler's Exposure Data PHI Preharvest Interval ppb Parts Per Billion PPE Personal Protective Equipment ppm Parts Per Million PRZM/EXAMS Tier II Surface Water Computer Model RAC Raw Agriculture Commodity RBC Red Blood Cell RED Reregi strati on Eligibility Decision REI Restricted Entry Interval RfD Reference Dose SCI-GROW Tier I Ground Water Computer Model SF Safety Factor TGAI Technical Grade Active Ingredient UF Uncertainty Factor jig micrograms |ig/L Micrograms Per Liter |iL/g Microliter per gram USDA United States Department of Agriculture WPS Worker Protection Standard 10 ------- APPENDIX II Citations Considered Part of the Data Base Supporting the Registration of GonaCon. MRID 47649600 47649601 47649602 47649603 47649604 47649605 47649606 47649607 47649608 47649609 Citation United States Department of Agriculture's Animal and Plant Health Inspection Service (USDA APHIS) (2009) Submission of Product Chemistry, Toxicity, Efficacy and Residue Data in Support of the Application for Registration of GonaCon Immunocontraceptive Vaccine. Transmittal of 36 Studies. O'Hare, J.; Eisemann, J. (2008) Description of Materials Used to Produce: "GoneCon Immunocontraceptive Vaccine". Project Number: P4417. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 168 p. O'Hare, J.; Eisemann, J. (2008) Description of Formulation Process Used to Manufacture: "GonaCon Immunocontraceptive Vaccine". Project Number: M8546, BT016/02. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 99 p. O'Hare, J.; Pilon, J.; Eisemann, J. (2008) Discussion of the Formation of Impurities "GonaCon Immunocontraceptive Vaccine". Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlive Research Center. 56 p. O'Hare, J.; Eisemann, J.; Pilon, J. (2008) Preliminary Analysis and Certified Limits "GonaCon Immunocontraceptive Vaccine": Final Report. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 9 p. O'Hare, J.; Eisemann, J. (2008) Enforcement Analytical Method: "GonaCon Immunocontraceptive Vaccine". Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 40 p. O'Hare, J.; Eisemann, J. (2007) Product Chemistry: Color, Physical State, Odor, and pH - USDA APHIS GonaCon Immunocontraceptive Vaccine (EPA Reg. No. 56228-xx): Final Report. Project Number: QA/1421. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 31 p. Warren, J.; Stephens, S. (2008) Stability to Normal and Elevated Temperatures, Metal, and Metal Ions: (Gonadotropin Releasing Hormone). Unpublished study prepared by US Dept. of Agriculture, APHIS, WS. 8 p. Warren, J.; Stephens, S. (2008) Oxidation/Reduction Chemical Incompatibility: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by US Dept. of Agriculture, APHIS, WS. 8 p. Warren, J.; Stephens, S. (2008) Flammability: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Receipt Date 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 11 ------- Warren, J.; Stephens, S. (2008) Explodability: (GonaCon 47649610 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. Warren, J.; Stephens, S. (2008) Miscibility: (GonaCon 47649611 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Corrosion Characteristics: (GonaCon 47649612 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Dielectric Breakdown Voltage: (GonaCon 47649613 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. 47649614 47649615 Warren, J.; Stephens, S. (2008) UV/Visible Absorption: (GonaCon Immunocontraceptive). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Viscosity: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Melting Point: (GonaCon 47649616 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Boiling Point: (GonoCon 47649617 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. Warren, J.; Stephens, S. (2008) Density/Relative Density/Bulk Density: 47649618 (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. Warren, J.; Stephens, S. (2008) Dissociation Constant in Water: 47649619 (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Octanol/Water Partition Coefficient: 47649620 (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Water Solubility: (GonaCon 47649621 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Warren, J.; Stephens, S. (2008) Vapour Pressure: (GonaCon 47649622 Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 8 p. Eisemann, J.; O'Hare, J. (2008) Chemical Identity: "GonaCon 47649623 Immunocontraceptive Vaccine". Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: Natiional Wildlife Research Center. 27 p. Eisemann, J.; O'Hare, J. (2008) Direction for Use: GonaCon Immunocontraceptive Vaccine. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Research Center. 12 p. 47649624 47649625 Lowe, C. (2008) GonaCon Immunocontraceptive Vaccine: Acute Oral 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 12 ------- 47649626 47649627 47649628 47649629 47649630 47649631 47649632 Toxicity - Limit Dose Procedure in Rats. Project Number: P320/USDA, 23211. Unpublished study prepared by Product Safety Laboratories. 28 p. Lowe, C. (2008) GonaCon Immunocontraceptive Vaccine: Acute Dermal Toxicity - Limit Dose Procedure in Rats. Project Number: 23212, P322/USDA. Unpublished study prepared by Product Safety Laboratories. 28 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Acute Inhalation Toxicity: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. Lowe, C. (2007) GonaCon Immunocontraceptive Vaccine: Primary Eye Irritation Study in Rabbits. Project Number: P324, 22806. Unpublished study prepared by Product Safety Laboratories. 29 p. Lowe, C. (2008) GonaCon Immunocontraceptive Vaccine: Primary Skin Irritation Study in Rabbits. Project Number: P326, 22807. Unpublished study prepared by Product Safety Laboratories. 27 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Dermal Sensitization: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Chronic Dietary Toxicity: (GonaCon Immunocontraceptive Vaccine). Unpublished study prepared by USDA APHIS. 4 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Gene Mutation: (GonaCon Immunocontraceptive Vaccine): (Human). Unpublished study prepared by USDA APHIS. 4 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Stuctural Chromosomal 47649633 Aberration: (GonaCon Immunocontraceptive Vaccine): (Human). Unpublished study prepared by USDA APHIS. 4 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Other Genotoxic Effects: 47649634 (GonaCon Immunocontraceptive Vaccine): (Human). Unpublished study prepared by USDA APHIS. 4 p. O'Hare, J.; Eisemann, J.; Stephens, S. (2008) Acute Delayed 47649635 Neurotoxicity: (GonaCon Immunocontraceptive Vaccine): (Hen). Unpublished study prepared by USDA APHIS. 4 p. Gionfriddo, J.; Eisemann, J.; O'Hare, J. (2008) Product Performance: Field Test of a Single-Injection of GonaCon Immunocontraceptive Vaccine 47649636 In Female White-Tailed Deer. Project Number: QA/1112. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS: National Wildlife Research Center. 31 p. 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 22-Jan- 2009 13 ------- |