Terbufos  IRED  Facts
                                                                            EPA 738-F-01-015
                                                                                October 2001

EPA has assessed the risks of terbufos and reached an Interim Reregistration Eligibility Decision
(IRED) for this organophosphate (OP) pesticide. Provided that risk mitigation measures are adopted,
terbufos fits into its own "risk cup" its individual, aggregate risks are within acceptable levels.
Terbufos also is eligible for reregistration, pending a full reassessment of the cumulative risk from all
OPs.

Used on corn, sorghum, and sugar beets, terbufos residues in food and drinking water do not pose
risk concerns with the implementation of certain risk mitigation measures. Terbufos has no residential
uses. With other risk reduction measures, terbufos's worker and ecological risks also will be
substantially reduced.

EPA's next step under the Food Quality Protection Act (FQPA) is to consider the cumulative risks of the
OP pesticides, which share a common mechanism of toxicity. The interim decision on terbufos cannot
be considered final until this consideration of OP risks is complete. Further risk mitigation may be
warranted at that time.

EPA is reviewing the OP pesticides to determine whether they meet current health and safety
standards. Older OPs need decisions about their eligibility for reregistration under FIFRA. OPs with
residues in  food, drinking  water, and other non-occupational exposures also must be reassessed to
make sure they meet the  new FFDCA safety standard, effected by the FQPA of 1996.

The terbufos interim decision was made through the OP pilot public participation process, which
increases transparency  and maximizes stakeholder involvement in EPA's development of risk
assessments and risk management decisions. EPA worked extensively with affected parties to reach
the decisions presented in this interim decision document, which concludes the OP pilot process for
terbufos.
Uses
       An insecticide, terbufos is used to control insects in corn, sorghum, and sugar beets. The
       major use is on corn to control soil insects such as; corn rootworm, wireworm, white grubs,
       seedcorn maggots, billbugs, and nematodes.

       According to Agency figures, annual domestic use is approximately 7.5 million pounds of
       active ingredient per year. Roughly 87% is used on corn.

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Health Effects

Terbufos can cause cholinesterase inhibition in humans; that is, it can overstimulate the nervous
system causing nausea, dizziness, confusion, and at very high exposures (e.g., accidents or major
spills), respiratory paralysis and death.

Risks

        Dietary exposures from eating food crops treated with terbufos are below the level of concern
        for the entire U.S. population, including infants and children.  Drinking water, however,  is a
        significant source of exposure

        EPA also has risk concerns for workers who load, and/or apply terbufos. For the Counter 15G
        formulation, there are risk concerns for both scenarios on each crop, whereas, the Counter
        20CR formulation in open bags only presents risk concerns for the loading scenario. There are
        no risk concerns for 20CR in lock-n-load containers.

        Terbufos presents high acute risks to non-target terrestrial wildlife species. Terbufos is  the
        leading cause of fish kill incidents reported to EPA for any pesticide applied to corn, and ranks
        fourth in fish kill incidents reported to EPA for any pesticide applied to any crop.  From 1976 to
        present, 96 fish kill incidents involving terbufos were reported to the Agency.

Benefits

The benefits of terbufos on corn were estimated using a comparative product performance
assessment. This assessment aimed at quantifying, to the extent possible, the benefits derived from
the use of terbufos on corn primarily for control of corn rootworm.

        The benefits assessment concluded that under most conditions the alternative insecticides
        produced similar or greater yields than fields where terbufos was used.

        Terbufos did show an advantage over the alternative insecticides in controlling billbugs  in
        North Carolina, corn rootworm in the Northeast, and some secondary corn pests.

Risk Mitigation

In order to support a reregistration eligibility decision for terbufos, the following risk mitigation
measures are necessary:

        To mitigate risks to agricultural workers:

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   Require the use of a closed loading system for the North Carolina Special Local Needs
    registration of Counter 20CR.

   Require that the Counter 15G  label be amended to indicate that applications must be made
    using enclosed cab tractors.

   Reduce the application rate on sorghum from 1.96 Ibs. active ingredient (a.i.) per acre to 1.7
    Ibs. a.i. per acre.

   To mitigate drinking water and ecological risks:

   Require a 55% reduction in sales of terbufos by 2008, based on 2000 sales figures.

   Require a 500 ft. vegetative buffer between treated area and surface water on neighboring
    land

   Require a 500 ft. vegetative buffer between a standpipe drain outlet and surface water on
    neighboring land.

   Require a 66 ft. setback between the treated area and entry points to surface water bodies on
    non-highly erodible soils.

   Require a 300 foot setback between the treated area and entry points to surface water bodies
    on highly erodible soils.

   Require a 66 ft. setback between treated area and standpipes on terraced fields as well as 66
    ft. vegetative buffer between the tile outlet and surface water bodies.

   Restrict loading, rinsing, and washing equipment within 300 ft. from surface water bodies or
    within 50 ft. from  wells unless conducted on an impervious surface.

   Remove the "over the top" application on corn for European corn borer control.

   Require placing granules for banded applications on corn in a 7 inch band over the row, in
    front of the press wheel, and incorporated into  the topi inch of soil.

   To prevent the flow of rainfall  down planted rows, the label text will be required to read "To
    prevent channeling of surface  water run-off, adjust the planter row-cleaners appropriately to
    prevent rows lower in height than adjacent soil".

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The OP Pilot Public Participation Process

The organophosphates are a group of related pesticides that affect the functioning of the nervous
system. They are among EPA's highest priority for review under the Food Quality Protection Act.

EPA is encouraging the public to participate in the review of the OP pesticides. Through a six-phased
pilot public participation  process, the Agency is releasing for review and comment its preliminary and
revised scientific risk assessments for individual OPs. (Please contact the OP Docket, telephone 703-
305-5805, or see EPA's web site, Pesticide Rereqistration Status.;)

EPA is exchanging information with stakeholders and the public about the OPs, their uses, and risks
through Technical Briefings, stakeholder meetings, and other fora. USDA is coordinating input from
growers and other OP pesticide users.

Based on current information from interested stakeholders and the public, EPA is making interim risk
management decisions for individual OP  pesticides, and will make final decisions through a cumulative
OP assessment.

Next Steps

For this IRED there will be a 60 day comment period before the document is finalized (see Pesticide
Rereqistration Status). In addition, the docket remains open and any comments submitted in the
future will be placed in this public docket.

When EPA has considered the cumulative risks of the OP pesticides, the Agency will issue its final
tolerance reassessment decision for terbufos and may request further risk mitigation measures. The
Agency will revoke 1 tolerance for terbufos, now. For all OPs, EPA will consider raising and/or
establishing tolerances once the cumulative risks of the OPs  have been considered.

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