United States      Prevention, Pesticides    EPA738-R-95-035
        Environmental Protection   And Toxic Substances    December 1995
        Agency	(7508W)	
&EPA  Reregistration
        Eligibility Decision (RED)
        Hydroxypropyl
        methanethiosulfonate

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
CERTIFIED MAIL
Dear Registrant:

       I am pleased to announce that the Environmental Protection Agency has completed its
reregistration eligibility review and decisions on the pesticide chemical case and active
ingredient hydroxypropyl methanethiosulfonate. The enclosed Reregistration Eligibility
Decision (RED) contains the Agency's evaluation of the data base of these chemicals, its
conclusions of the potential human health and environmental risks of the current product uses,
and its decisions and conditions under which these uses and products will be eligible  for
reregistration. The RED includes the data and labeling requirements for products for
reregistration. It may also include requirements for additional data (generic) on the active
ingredients to confirm the risk assessments.

       To assist you with a proper response, read the enclosed document entitled  "Summary
of Instructions for Responding to the RED." This summary also refers to other enclosed
documents which include further instructions. You  must follow all instructions and submit
complete and timely responses. The first set of required responses is due 90 days  from the
receipt of this letter.  The second  set of required responses is due 8 months from the date
of this letter.  Complete and timely responses will avoid the Agency taking the enforcement
action of suspension against your products.

       If you have questions on the product  specific data requirements or wish to  meet with
the Agency, please contact the Special  Review and Reregistration Division representative
Moana Appleyard (703)  308-8175.  Address any questions on required generic data to the
Special Review and Reregistration Division  representative Patrick Dobak (703) 308-8180.

                                                     Sincerely yours,
                                                     Lois Rossi, Division Director
                                                     Special Review
                                                     and Reregistration Division
Enclosures

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              SUMMARY OF INSTRUCTIONS FOR RESPONDING TO
             THE REREGISTRATION ELIGIBILITY DECISION (RED)

1.  DATA CALL-IN (PCI) OR "90-DAY RESPONSE"  If generic data are required for
reregistration, a DCI letter will be enclosed describing such data.  If product specific data
are required, a DCI letter will be enclosed listing such requirements.  If both generic and
product specific data are required, a combined Generic and Product Specific DCI letter will
be enclosed describing such data.  However, if you are an end-use product registrant only  and
have been granted a generic data exemption (GDE) by EPA, you are being sent only the
product specific response forms (2 forms) with the RED.  Registrants responsible for generic
data are being sent response forms for both generic and product specific data requirements (4
forms).  You must submit  the appropriate response forms (following the instructions
provided) within 90 days of the receipt of this RED/DCI letter; otherwise, your product
may be suspended.

2.  TIME EXTENSIONS AND DATA WAIVER REQUESTS No time extension requests
will be granted for the 90-day response.  Time extension requests may be submitted only with
respect to actual data submissions.  Requests for time  extensions for product specific data
should be submitted in the 90-day response.  Requests for  data waivers must be submitted  as
part of the 90-day response.  All data waiver and time extension requests must be accompanied
by a full justification. All waivers and time extensions must be granted by EPA in order to go
into effect.

3.  APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE"  You must
submit the following items for each product within eight months of the date of this letter
(RED issuance date).

      a. Application for Reregistration (EPA Form 8570-1). Use only an original
application form.  Mark it "Application for Reregistration."  Send your Application for
Reregistration (along with the other forms listed in b-e below) to the address listed in item 5.

      b. Five copies of draft labeling which complies with the RED and current regulations
and requirements.  Only make labeling changes which are  required by the  RED and current
regulations (40 CFR 156.10) and policies.  Submit any other amendments  (such as formulation
changes, or labeling changes not related to reregistration) separately.  You may, but are not
required to, delete uses which the RED says are ineligible  for reregistration.  For further
labeling guidance, refer to the labeling section of the EPA publication "General Information
on Applying for Registration in the U.S., Second Edition,  August 1992" (available from the
National Technical Information Service, publication #PB92-221811;  telephone number 703-
487-4650).

      c. Generic or Product Specific Data. Submit all data in a format which complies
with PR Notice 86-5, and/or submit citations of data already submitted and give the EPA
identifier (MRID) numbers.  Before citing these studies, you must make sure that they meet
the Agency's acceptance criteria (attached to the DCI).

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      d. Two copies of the Confidential Statement of Formula (CSF) for each basic and
each alternate formulation.  The labeling and CSF which you submit for each product must
comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal
concentration.  You have two options for submitting a CSF: (1) accept the standard certified
limits  (see 40 CFR §158.175) or (2) provide certified limits that are supported by the analysis
of five batches.  If you choose the second option, you must submit or cite the data for the five
batches along with a certification statement as described in 40 CFR §158.175(e).  A copy of
the CSF is enclosed; follow the instructions on its back.

      e. Certification With Respect to Data Compensation Requirements.  Complete and
sign EPA form  8570-31 for each product.

4. COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE Comments
pertaining to the content of the RED may be submitted to the address shown in the Federal
Register Notice which announces the availability of this RED.

5. WHERE TO SEND PRODUCT SPECIFIC PCI RESPONSES (90-DAY) AND
APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      EPA, 401 M St. S.W.
      Washington, D.C. 20460-0001

By express:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      Room 266A, Crystal Mall 2
      1921 Jefferson Davis Hwy.
      Arlington, VA 22202

6. EPA'S REVIEWS—EPA will screen all submissions for completeness; those which are not
complete will be returned with a request for corrections. EPA will try to respond to data
waiver and time extension requests within  60 days. EPA will also try to respond to all 8-
month submissions with a final reregistration determination within 14 months after the RED
has been issued.

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   REREGISTRATION ELIGIBILITY DECISION

HYDROXYPROPYLMETHANETHIOSULFONATE

                      LISTC

                    CASE 3033
               ENVIRONMENTAL PROTECTION AGENCY
                 OFFICE OF PESTICIDE PROGRAMS
            SPECIAL REVIEW AND REREGISTRATION DIVISION

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                         TABLE OF CONTENTS
HYDROXYPROPYL METHANETHIOSULFONATE REREGISTRATION ELIGIBILITY
      DECISION TEAM	i

EXECUTIVE SUMMARY	v

I.     INTRODUCTION	1

II.    CASE OVERVIEW	2
      A.    Chemical Overview 	2
      B.    Use Profile 	2
      C.    Estimated Usage of Pesticide  	4
      D.    Regulatory History and Data Requirements  	4

III.   SCIENCE ASSESSMENT	4
      A.    Physical Chemistry Assessment	4
      B.    Human Health Assessment	5
           1.    Toxicology Assessment	5
                 a.    Acute Toxicity  	5
                 b.    Subchronic Toxicity	6
                 c.    Chronic Toxicity/Carcinogenicity	7
                 d.    Developmental Toxicity  	7
                 e.    Reproductive Toxicity  	7
                 f.     Mutagenicity  	8
                 g.    Metabolism  	8
                 h.    Toxic Endpoints of Concern  	8
           2.    Exposure and Risk Assessment	9
                 a.    Dietary Exposure and Risk Assessment	9
                 b.    Occupational and Residential Exposure and Risk Assessment
                         	9
      C.    Environmental Assessment	10
           1.    Ecological Toxicity Data  	10
                 a.    Toxicity to Terrestrial Animals  	10
                 b.    Toxicity to Aquatic Animals  	11
                 c.    Toxicity to Plants  	13
           2.    Environmental Fate   	13
                 a.    Environmental Fate Assessment	13
                 b.    Environmental Fate and Transport  	13
           3.    Exposure and Risk Characterization  	14

IV.   RISK MANAGEMENT AND REREGISTRATION DECISION	14
      A.    Determination of Eligibility	14

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      B.    Determination of Eligibility Decision	15
            1.     Eligibility Decision  	15
            2.     Eligible and Ineligible Uses   	15
            3.     Endangered Species Protection	15
      C.    Regulatory Position  	15
            1.     Risk Mitigation Measures/ Labeling Rationale	16
            2.     Entry Restrictions	17
            3.     Addition and Retention of Other Label Statements	17

V.    ACTIONS REQUIRED OF REGISTRANTS 	17
      A.    Manufacturing-Use Products	17
            1.     Additional Generic Data Requirements	17
            2.     Labeling Requirements for Manufacturing-Use Products	18
      B.    End-Use Products  	18
            1.     Additional Product-Specific Data Requirements	18
            2.     Labeling Requirements for End-Use Products	19
      C.    Existing Stocks 	21

VI.   APPENDICES  	23
      APPENDIX A.    Table of Use Patterns Subject to Reregistration  	24
      APPENDIX B.    Table of the Generic Data Requirements and Studies Used to
            Make the Reregistration Decision	33
      APPENDIX C.    Citations Considered to be Part of the Data Base Supporting the
            Reregistration of Hydroxypropyl methanethiosulfonate   	39
      APPENDIX D.    Product Specific Data Call-in  	45
            Attachment 1.     Chemical Status Sheets	59
            Attachment 2.     Product Specific Data Call-in Response Forms (Form A
                  inserts)  Plus Instructions  	60
            Attachment 3.     Product Specific Requirement Status and Registrant's
                  Response Forms (Form B inserts) and Instructions	62
            Attachment 4.     EPA  Batching of End-Use Products for Meeting Data
                  Requirements for Reregistration	69
            Attachment 5.     List of All Registrants Sent This Data Call-in (insert)
                  Notice	73
            Attachment 6.     Cost  Share, Data Compensation Forms,  Confidential
                  Statement of Formula Form and Instructions 	74
      APPENDIX E.    List of Available Related Documents	82

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HYDROXYPROPYL METHANETHIOSULFONATE REREGISTRATION
ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:

Biological and Economic Analysis Assessment
Ghulam Ali
Steve Jarboe
Cynthia Szymanski

Environmental Fate and Effects Assessment

Ann Stavola
Mary Frankenberry
Rachelle Kudrik
Jose Melendez

Health  Effects Assessment

Arliene Aikens
Tom Campbell
Paula Deschamp
Steven  Malish

Registration Support

Valdis  Goncarovs
Tina Levine
Shyam  Mathur

Risk Management

Kathleen Depukat
Patrick Dobak

Office  of Compliance:

Carol Buckingham
Economic Analysis Branch
Biological Analysis Branch
Biological Analysis Branch
Ecological Effects Branch
Science Analysis and Coordination Staff
Science Analysis and Coordination Staff
Environmental Fate and Groundwater Branch
Risk Characterization and Analysis Branch
Occupational and Residential Exposure Branch
Risk Characterization and Analysis Branch
Toxicology Branch II
Antimicrobial Program Branch
Reregistration Support Branch
Reregistration Support Branch
Accelerated Reregistration Branch
Accelerated Reregistration Branch
Agriculture and Ecosystem Division

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               11

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            GLOSSARY OF TERMS AND ABBREVIATIONS

ADI            Acceptable Daily Intake.  A now defunct term for reference dose (RfD).
AE            Acid Equivalent
a.i.            Active Ingredient
ARC           Anticipated Residue Contribution
CAS           Chemical Abstracts Service
CI             Cation
CNS           Central Nervous  System
CSF           Confidential Statement of Formula
DFR           Dislodgeable Foliar Residue
ORES          Dietary Risk Evaluation System
DWEL         Drinking Water Equivalent Level (DWEL) The DWEL represents a medium specific (i.e.
               drinking water) lifetime exposure at which adverse, non carcinogenic health effects are not
               anticipated to occur.
EEC           Estimated Environmental Concentration. The estimated pesticide concentration in an
               environment, such as a terrestrial ecosystem.
EP            End-Use  Product
EPA           U.S. Environmental Protection Agency
FDA           Food and Drug Administration
FIFRA         Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA        Federal Food, Drug, and Cosmetic Act
FOB           Functional Observation Battery
GLC           Gas Liquid Chromatography
GM           Geometric Mean
GRAS          Generally Recognized as Safe as Designated by FDA
HA            Health Advisory  (HA).  The HA values are used as informal guidance to municipalities and
               other organizations when emergency spills or contamination situations occur.
HOT           Highest Dose Tested
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.
LDlo           Lethal Dose-low. Lowest Dose at which lethality occurs.
LEL           Lowest Effect  Level
LOG           Level of Concern
LOD           Limit of Detection
LOEL          Lowest Observed Effect Level
MATC         Maximum Acceptable Toxicant Concentration
MCLG         Maximum Contaminant Level Goal (MCLG)  The MCLG is used by the Agency to regulate
               contaminants in drinking water under the Safe Drinking Water Act.
Hg/g           Micrograms Per Gram
mg/L           Milligrams Per Liter
MOE           Margin of Exposure
MP            Manufacturing-Use Product
MPI           Maximum Permissible Intake
MRID          Master Record Identification (number).  EPA's system of recording and tracking studies
               submitted.
N/A           Not Applicable
NOEC          No effect concentration
                                                 111

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            GLOSSARY  OF TERMS AND ABBREVIATIONS

NPDES        National Pollutant Discharge Elimination System
NOEL          No Observed Effect Level
NOAEL        No Observed Adverse Effect Level
OP            Organophosphate
OPP           Office of Pesticide Programs
PADI          Provisional Acceptable Daily Intake
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
PRN           Pesticide Registration Notice
Q*!            The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model
RBC           Red Blood Cell
RED           Reregistration Eligibility Decision
REI            Restricted Entry Interval
RfD           Reference Dose
RS            Registration Standard
SLN           Special Local Need (Registrations Under Section 24 (c) of FIFRA)
TC            Toxic Concentration. The concentration at which a substance produces a toxic effect.
TD            Toxic Dose. The dose at which a substance produces a toxic effect.
TEP           Typical End-Use Product
TGAI          Technical Grade Active Ingredient
TLC           Thin Layer Chromatography
TMRC         Theoretical Maximum Residue Contribution
torr            A unit of pressure needed to support a column of mercury 1 mm high under standard conditions.
FAO/WHO     Food and Agriculture Organization/World Health Organization
WP            Wettable Powder
WPS           Worker Protection Standard
                                                IV

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EXECUTIVE SUMMARY

       As required under the Federal Insecticide, Fungicide, and Rodenticide Act, as amended
in 1988, the U.S. Environmental Protection Agency has completed its reregistration eligibility
decision for the pesticide active ingredient hydroxypropyl methanethiosulfonate (HPMTS).
This decision includes a comprehensive reassessment of the required target data base and use
patterns of currently registered products.  The Agency compared its risk assessment to current
science and regulatory policies. The Agency has determined that the uses as described below
will not cause unreasonable risk to humans or the environment and all uses are eligible for
reregistration. Where appropriate, the Agency has imposed additional use restrictions and
precautionary statements for product labels to reduce risks to human health and the
environment.

       Use Patterns

       HPMTS is a microbiocide/microbiostat used to control slime-forming algae, bacteria,
and fungi in commercial/industrial water cooling systems, industrial processing water,
pulp/paper mill water systems, and is used as a preservative in industrial coatings, emulsions,
paints and wet-end additives/industrial processing chemicals.  It is applied by direct pouring
and metered application.

       Human Health Assessment

       From its review of the toxicology data,  the Agency concluded that HPMTS is mildly to
moderately toxic when administered by oral or dermal routes.  The chemical is corrosive and
is considered to be a severe dermal and eye irritant. The chemical caused delayed contact
hypersensitivity in the guinea pig dermal sensitization studies.  The subchronic dermal LOEL
was determined to be 250 mg/kg/day for systemic toxicity and 10 mg/kg/day for dermal
toxicity.  A battery of mutagenicity studies was negative for mutagenic effects. Two
developmental toxicology studies were reviewed.  The rat maternal LOEL and NOEL were
determined to be 30 mg/kg/day and 10 mg/kg/day, respectively. The rabbit maternal LOEL
and NOEL were determined to be 4.0 mg/kg/day and 0.75 mg/kg/day, respectively.

       No dietary exposure to  HPMTS is expected from the current use patterns.  Although
corrosiveness and dermal sensitization were identified as potential effects, significant
occupational exposures are not expected.  Therefore, quantitative assessments of exposures
and risks were deemed unnecessary and not conducted. To mitigate the potential risks of
corrosiveness and dermal sensitization to workers, minimum (baseline) personal protective
equipment  (PPE) is being required for the handling of concentrated products. Non-
occupational exposures are not expected.

       Environmental Assessment

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       HPMTS is moderately toxic to slightly toxic to avian species on an acute and subacute
oral dietary basis, slightly toxic to fish, and moderately toxic to aquatic invertebrates.  Current
uses of HPMTS are expected to result in minimal exposure or risk to the environment.
Therefore, no additional environmental risk mitigation measures are being imposed at this
time.

       Product Reregistration

       The Agency is requiring that product specific data, revised Confidential Statements of
Formula (CSF) and revised labeling be submitted within eight months of the issuance of this
document for all products containing HPMTS.  These data include product chemistry and
acute toxicity testing for each registration.  After reviewing these revised labels and finding
them acceptable in accordance with Section 3(c)(5) of FIFRA, the Agency will reregister each
associated product. Those products that contain other active ingredients will be eligible for
reregistration only when the other active ingredients are determined to be eligible for
reregistration.
                                            VI

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended
to accelerate the reregistration of products with active ingredients registered prior to November
1,  1984. The amended Act provides a schedule for the  reregistration process to be completed in
nine years. There are five phases to the reregistration process. The first four phases of the process
focus on identification of data requirements to support the  reregistration of an active ingredient
and the generation and submission of data to fulfill the requirements.  The fifth phase is a review
by the U.S. Environmental Protection Agency (referred to as "the Agency") of all data submitted
to support reregistration.

       FIFRA Section 4(g)(2)(A)  states that in Phase  5  "the Administrator shall determine
whether pesticides containing such active ingredient are  eligible for reregistration" before calling
in  data  on products and either reregistering products or taking "other appropriate regulatory
action."  Thus, reregistration involves a thorough review  of the scientific data base underlying a
pesticide's registration.  The purpose of the Agency's review is to reassess the potential  hazards
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  the pesticide meets the "no
unreasonable adverse effects"  criterion of FIFRA.

       This document presents the Agency's decision  regarding the reregistration eligibility of
the registered uses of 2-hydroxypropyl methanethiosulfonate (HPMTS). The document  consists
of six sections. Section I is  the  introduction. Section  II describes HPMTS,  its uses,  data
requirements and regulatory history.  Section III discusses  the human health and environmental
assessment  based  on the data available  to  the Agency.  Section IV presents the reregistration
decision for HPMTS. Section  V discusses the reregistration requirements for HPMTS.  Finally,
Section  VI is the Appendices which support this Reregistration Eligibility Decision. Additional
details concerning the Agency's review of applicable data are  available on request.

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II.    CASE OVERVIEW

      A.     Chemical Overview

             The following  active  ingredient is covered by this Reregistration  Eligibility
      Decision:

      •      Common Name:           HPMTS

      •      Chemical Name:           2-hydroxypropyl methanethiosulfonate

      •      Chemical Family:         Thiosulfonates

      •      CAS Registry Number:    30388-01-3

      •      OPP Chemical Code:      35604

      •      Empirical Formula:        C4HnS203

      •      Trade and Other Names:   S-(2-hydroxypropyl) thiomethanesulfonate

      •      Basic Manufacturer:       Buckman Labs

      B.     Use Profile

             The following is information on the currently  registered uses with an overview of
      use sites and application methods.  A detailed table  of these  uses of HPMTS is in
      Appendix A.

      For 2-hydroxypropyl methanethiosulfonate:

      Type of Pesticide:   Microbiocide/microbiostat  (slime-forming algae,  bacteria  and
                         fungi), Bacteriostat.

      Use Sites:          AQUATIC NON-FOOD INDUSTRIAL

                                Commercial/Industrial  Water Cooling Systems
                                Industrial Processing Water
                                Pulp/Paper Mill Water Systems

                         INDOOR NON-FOOD

                                Industrial Coatings
                                Resin/Latex/Polymer Emulsions

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                          Latex/Oil/Varnish Paints (Applied Film)
                          Wet-End Additives/Industrial Processing  Chemicals
Target Pests: Slime-forming algae, bacteria and fungi

                                 End-use, Manufacturing-use
Formulation Types  TYPE:
Registered:
                    FORM:
                    PURITY:
Soluble Concentrate/Liquid, Ready-To-Use Solution
/Liquid

Single Active Ingredient
TGAI: 80%
End-Use Products: 5-80%
Multiple Active Ingredients
End-Use Products: 11.7-28%
Method and Rates   Equipment - Direct pour, metered application (registrant must
of Application:      specify on labeling). For Rates of application see Table 1 below.

                    Timing - During manufacture, Not specified (registrant must supply
                    on labeling).
Table 1 - Method and Rate
TREATMENT
TYPE
Water (recirculating)
Water (recirculating)
Water
Industrial
Preservative
Industrial
Preservative
Industrial
Preservative
Industrial
Preservative
SYSTEM TYPE
Commercial/Industrial Cooling Systems
Industrial Processing
Pulp/Papermill
Industrial Coatings
Resin/Latex/Polymer Emulsions
Latex/Oil/Varnish Paints (applied film)
Wet-End Additives/ Industrial Processing
Chemicals
RATE (ppm AI
by weight)
0.4 to 8. 5
0.4 to 4. 3
0.176 to 281
400 to 4050
400 to 4050
280 to 2800
400 to 4050

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       Use Practice
       Limitations:         NPDES license restriction.

       C.    Estimated Usage of Pesticide

             Information about the use and percentage of sites treated with  HPMTS is not
       readily available.  However, the aggregate annual use of this pesticide is considered to be
       quite small in the United States, based on proprietary sources.

       D.    Regulatory History and Data Requirements

             Products containing HPMTS as an active ingredient were registered in the United
       States as early as  1968.  Currently, nine products  are registered to one registrant for the
       uses described above.

             In March, 1987, the Agency issued the Anti-Microbial Data Call-In Notice for
       toxicity and exposure data requirements for this active ingredient  and other antimicrobials.
       Additionally, the Agency  issued  a September, 1992 Phase IV Data Call-In requiring
       studies on product chemistry, human health, and ecological effects data to support the uses
       listed. Appendix B includes all data requirements  identified by the Agency for currently
       registered uses needed to support reregistration.

III.    SCIENCE ASSESSMENT

       A.    Physical Chemistry Assessment

             Molecular Weight:   171.25

             Color:               Light yellow/brilliant yellow

             Odor:               Strong sour, pungent vegetable-like odor

             Boiling Point:        164°C

             Density:             1.2893  at 22°C
             Solubility:

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Table 2 - HPMTS Solubility
Solvent
Ethanol
Hexane
C8_18 Fatty Acids
Water
Solubility
Miscible in all proportions
< 16 mg in 100 ml
Mean fat solubility at 37 °C
At concentrations > 40%,
concentrations < 40%, not
is5.42 + 0.04g/100g
soluble at any concentration; at
completely soluble
              Vapor Pressure:     1.40 mm Hg at 20°C and 1.70 mm Hg at 25°C.

              pH:                 3.7at22°C.

       B.     Human Health Assessment

              1.     Toxicology Assessment

                    The toxicological data base on HPMTS is adequate to support reregistration
              eligibility.

                    a.     Acute Toxicity
Table 3 - Acute Human Health Studies
Type of Study
Acute Oral - rat
Acute Dermal - rat
Acute Inhalation
Primary Eye Irritation*
Primary Dermal Irritation*
Dermal Sensitization - guinea pig*
Results [mg/kg]
LD5n  2000
Waived
Waived
Waived
Sensitizer
Toxicity Category
II
III
NA
I
I
NA
* This study is a requirement for manufacturing-use and end-use products (40 CFR 158).
applicable
NA = not
                           In an acute oral toxicity study in the rat, HPMTS (81.45% a.i.) was
                    administered by oral gavage to 5 animals/sex and observed for 14 days.
                                            5

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Compound related clinical signs presented were transient hypoactivity and
staggered gait in surviving rats. Reddening of glandular stomach mucosa
and the gastrointestinal tract were seen. (MRID 41634701)

       In an acute dermal toxicity study in the rat, HPMTS (81.45% a.i.)
was  administered by dermal  application at  2  gm/kg  (limit  dose) to 5
animals/sex for 14 days.  Dermal irritation was present in all animals and
included erythema, edema, fissuring, hemorrhaging, blanching,  atonia, and
a leathery feel to the skin.  The dose used in the study was the limit dose
specified in the guidelines. (MRID 41632401)

       An acute inhalation study was waived  because the absence  for
potential for inhalation exposure (no respirable particles) is indicated by the
current HPMTS use pattern.  The  primary dermal irritation and eye
irritation studies were waived because HPMTS was corrosive in the 14 and
90-day dermal studies.

       In a guinea pig dermal sensitization study, HPMTS (40%  a.i.) was
found to be a sensitizer. HPMTS caused delayed contact hypersensitivity.
(MRID 42349201)

b.     Subchronic  Toxicity

       In  a two-week, repeat dose (range finding), dermal toxicity study
conducted in the rat, HPMTS (79.67% a.i.) as a  30% solution  [in distilled
water] was applied to 5 animals/sex at doses of 0, 100, 250, 500, 750 or
1000 mg/kg/day, for 6 hours/day,  5 days/week for 14  days.   Control
animals received distilled water.  A dose related irritation was presented
with eschar, and exfoliation at 500 to 750 mg/kg/day.  The dermal no
observable effect level (NOEL) was < 100  mg/kg/day (lowest dose tested).
(MRID 40747102)

       In  a dermal toxicity study in rats,  HPMTS  (79.67% a.i.), at a
concentration  of 5.0%, was applied to approximately  10% of  the body
surface area of 10 animals/sex at doses of 0, 10, 50 or 250 mg/kg/day.
Exposure was for 6 hours/day, 5 days/week for 91 days.  Control animals
received distilled water under the same experimental conditions.

       Slight  treatment-related  reductions  in  body weight and food
consumption  were  found in the  high dose males.  Compound-related
reductions in erythrocyte counts, hematocrit and hemoglobin occurred in
both high dose males and females as compared to the respective  controls.
A slight but significant increase in the platelet count occurred in the high
dose in both sexes.

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       Compound  and dose-related dermal irritation was  found in  the
treated animals at the application site.  The severity of the irritation ranged
from minimal in the low-dose animals to severe in the high-dose animals
of  both  sexes.  Surface  exudate,  dermal  inflammation,  and  fibrosis
occasionally  accompanied  the ulceration  in  the high-dose  animals.
Microscopic examination confirmed the gross observation of the skin in the
high dose animals as ulceration and acanthotic epidermal thickening.

       Based on changes in body weights and hematology at the high dose,
the lowest observable effect level  (LOEL)  for systemic toxicity is 250
mg/kg/day and the NOEL is 50 mg/kg/day. The LOEL for dermal toxicity
is  10 mg/kg/day, the lowest dose tested. (MRID 40974701)

c.      Chronic Toxicity/Carcinogenicity

       Chronic toxicity and carcinogenicity studies are not required for
HPMTS because the non-food use pattern scenarios currently registered are
not likely to result in significant human exposure.

d.     Developmental Toxicity

       A developmental toxicity study conducted in the rat,  evaluated
HPMTS  (79.67% a.i.) at doses of 0, 10, 30 or 75 mg/kg/day by gavage
from gestation days 6 to 15. The maternal NOEL was 10 mg/kg/day and
the maternal LOEL was 30 mg/kg/day based on salivation, rales, and oral-
nasal  discharge.  The developmental NOEL was  10 mg/kg/day  and  the
developmental LOEL was  30 mg/kg/day based on reduced fetal weight.
(MRID 41010501)

       Another developmental toxicity study conducted by gavage in the
rabbit, evaluated HPMTS  (79.67%) at doses of 0, 0.75, 4.0 or  7.5
mg/kg/day from gestation days 6 to 18.  The maternal NOEL and LOEL
were 0.75 mg/kg/day and 4.0 mg/kg/day, respectively, based on decreased
body  weights.  The developmental  NOEL was >7.5 mg/kg/day (HDT).
(MRID 41010401)

e.      Reproductive Toxicity

       A  reproductive toxicity study  is not required  to  support  the
currently registered non-food uses of HPMTS because  the use pattern
scenarios are not likely to result in significant human exposure.

f.      Mutagenicity

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             In a gene mutation (Reverse Mutation)  study, HPMTS  (79.67%
       a.i.)  did not produce gene  mutation in an Ames  assay  in which S.
       typhimurium (TA98, TA100, TA1535 and TA1538) bacteria were tested
       without activation up to 0.25 jjl/plate and with activation up to 0.5  jjl/plate.
       Concentrations >0.5 jjl/plate produced cytotoxicity.  (MRID 40229601)

              HPMTS (80% a.i.) was negative both with and without activation
       in a Sister Chromatid Exchange (SCE) In Vitro/'CHO assay when assayed
       at concentrations into the toxic range (16.7 jig/ml).  (MRID 40420201)

             In the DNA Damage/Repair in Primary Rat Hepatocytes  study,
       HPMTS (80% a.i.) was negative for inducing UDS at concentration levels
       into the toxic range (100 jig/ml and higher). (MRID 40420202)

       g.     Metabolism

             A metabolism study is not required  to support non-food uses of
       HPMTS because of the expected absence of oral  exposure and because the
       current use pattern scenarios are not likely to result in significant human
       exposure.

       h.     Toxic Endpoints of Concern

             Based on HPMTS' target database  for toxicology, the Agency
       concludes there are no toxicological endpoints  of concern  for HPMTS.
       While technical HPMTS has been demonstrated to be corrosive and lead to
       dermal  sensitization from acute  exposures, these concerns are  more
       appropriately addressed during product reregistration after a re-assessment
       of each product's acute toxicity.

       Reference Dose (RED)

             A reference dose was not established for HPMTS, based on the non-
       food  use patterns and exposure profile (The Agency's Office of Pesticide
       Programs RfD Committee report, February 15,  1995)

       WHO/JMPR Status

             The World Health Organization/Joint Meeting on Pesticide Residues
       committee has not reviewed this pesticide.

2.     Exposure and Risk Assessment

       a.     Dietary Exposure and Risk Assessment
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                    There are no registered food uses of HPMTS, therefore, a dietary
              exposure and risk assessment are not required.

              b.     Occupational and Residential Exposure and Risk Assessment

                    An occupational/residential exposure assessment is required for an
              active ingredient if:  (1)  certain toxicological criteria are triggered and (2)
              there is potential exposure to handlers (M/L/A) during use or to persons
              entering treated sites  after  application  is complete.  Since  toxicology
              endpoints  of concern, except for corrosiveness and dermal sensitization
              from acute exposures, were not identified for  occupational/residential
              exposures,  an  occupational/residential  M/L/A  exposure analysis and
              quantitative risk assessment are not warranted at this time.

                    The Agency has  determined that products containing  HPMTS
              labeled and used as  specified in this RED will not pose significant risk to
              humans. The most significant occupational concerns are for corrosiveness
              and dermal sensitization from acute  exposures.   The  use  of minimal
              (baseline)  PPE  , including chemical  resistant  gloves  and  apron and
              faceshield, will adequately mitigate these hazards.

                    A short term  (1 to 7 days) occupational/residential risk  assessment
              is not required, since results from the 14-day dermal toxicity study do not
              indicate any toxicological  endpoints appropriate for use in the standard
              occupational or residential exposure assessments.  Also, an intermediate (1
              week to several months) occupational/residential risk assessment is not
              required based on a comparison of the 90-day repeated-dose dermal toxicity
              and the  oral developmental  toxicity studies  conducted in rats.  In these
              studies, the LOEL(s) were 250 mg/kg/day and 30 mg/kg/day, respectively.
              On  the  basis  that the  dermal LOEL was  significantly higher, it was
              determined that dermal absorption of HPMTS is limited.  Also, inhalation
              exposures are not expected because respirable particles are not anticipated
              to be produced from  the application methods (open-pour or metered pump)
              and because of the chemical's low vapor pressure.

                    Most of HPMTS' use and exposure are associated with industrial
              applications.  Additionally, people who apply HPMTS treated paint or who
              reside or work in buildings which have painted with such paint may also be
              exposed to HPMTS. However,  because of the Agency's conclusion on
              HPMTS' risks from subchronic exposures and because  of HPMTS' low
              vapor pressure, the Agency believes risks to these individuals are very low.
C.     Environmental Assessment

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1.      Ecological Toxicity Data

       a.      Toxicity to Terrestrial Animals

              (1)    Birds, Acute and Subacute

                    In order to establish the toxicity of HPMTS to birds, the
              following tests are required for industrial microbiocides using the
              technical grade material:  one avian single-dose oral (LD50) study
              on one species (preferably the bobwhite quail or mallard duck);  one
              subacute  dietary  study  (LC50) on one  species  (preferably  the
              bobwhite quail).   The available information is summarized in the
              following tables:
Table 4 - Avian Acute Oral Toxicity Findings
Species
Mallard Duck
% A.I.
79.82
LD50 mg/kg
>474.4 mg/kg
Toxicity Category
moderately toxic
                    Although  the  avian  acute  oral  study  yielded  some
              information, it was not considered acceptable  because  the birds
              regurgitated shortly after dosing.  The registrant is performing a
              new study in order to fulfill guideline requirements.
Table 5 - Avian Subacute Dietary Toxicity Findings
Species
Northern Bobwhite Quail
Mallard Duck
% A.I.
79.82
79.82
LC50 ppm
>3991
>3991
Toxicity Category
slightly toxic
slightly toxic
                    The results from the subacute study and the supplemental
              results of the acute oral study indicate that HPMTS is slightly to
              moderately toxic  to avian species on  an acute oral and subacute
              dietary basis. (MRID 249523 for all three)

              (2)    Birds, Chronic

                    Avian reproduction studies are required when birds may be
              exposed  repeatedly   or  continuously  through  persistence,
              bioaccumulation,   or  multiple applications, or   if mammalian
              reproduction tests indicate reproductive hazard. Since the currently
                              10

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       registered uses are for indoor use only, repeated exposures are not
       expected and chronic avian studies are not required.
       (3)
       Mammals
b.
       Wild mammal testing is required on a case-by-case basis,
depending on the results of the lower tier studies such as acute and
subacute testing, intended use pattern, and pertinent environmental
fate characteristics.  In most cases, however, an acute oral LD50 is
used to indicate toxicity to  mammals.   The LD50, as reported in
Table 3 above,  indicates that HPMTS is slightly toxic to small
mammals on an acute oral basis. No additional testing on mammals
is required for these use patterns. (MRID  41634701)

Toxicity to Aquatic Animals

(1)     Freshwater Fish
              (a)
              Acute
                    In order to establish the toxicity  of a pesticide to
              freshwater fish, the minimum data required for industrial
              microbiocides is one freshwater fish toxicity study on the
              technical grade of the active ingredient.  The study should
              preferably use the rainbow trout (cold water species) or the
              bluegill  sunfish  (warm  water species).   The available
              information is summarized in the following table.
Table 6 - Freshwater Fish Acute Toxicity Findings
Species
Rainbow trout
Bluegill sunfish
% A.I.
81.45
81.45
LC50 (ppm)
28.0
38.2
Toxicity Category
slightly toxic
slightly toxic
                    The results  of  the  96-hour acute  toxicity studies
              indicate that HPMTS is slightly toxic to both cold and warm
              water fish.  The guideline  requirements  are  fulfilled.
              (MRIDs 41733203 and 41733201,  respectively)

              (b)    Chronic
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              The fish early life-stage and fish life-cycle tests are
       not required because the products are not applied directly to
       water  or  expected to be transported to water  from the
       intended use site.  Additionally, the fish early life-stage test
       is not required because the LC50 in this case is greater than
       1 mg/L.

(2)     Freshwater Invertebrates

       (a)     Freshwater Invertebrates,  Acute

              The  minimum testing required to  establish the
       toxicity of a microbiocide to freshwater invertebrates is a
       freshwater aquatic invertebrate  toxicity test, preferably
       using first instar Daphnia magna or early instar amphipods,
       stoneflies, mayflies, or midges.  The results of the toxicity
       findings are presented in the table below.
Table 7 - Freshwater Invertebrate Toxicity Findings
Species
Daphnia magna
% A.I.
79.82
EC50 (ppm)
3.13
Toxicity Category
moderately toxic
(3)
       There  is sufficient  information to  characterize
HPMTS as moderately toxic to aquatic invertebrates. The
guideline requirement is fulfilled.  (MRID 41733202)

(b)    Freshwater Invertebrates, Chronic

       The same conditions for chronic testing to freshwater
fish also apply to aquatic invertebrates as discussed in (l.b.)
above. Chronic aquatic invertebrate studies are not required
for HPMTS.

Estuarine and Marine Animals
       (a)
       Acute
              Although  estuarine/marine  testing was originally
       required,  a  waiver  for those  data  requirements was
       subsequently  granted  in  response  to  the  registrants'
       incorporation of a statement on all HPMTS labels restricting
                12

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                    the discharge of HPMTS directly or indirectly into estuarine
                    or marine environments to NPDES permitted discharges.

                    (b)    Chronic

                           The same conditions for chronic testing to freshwater
                    fish and aquatic invertebrates also apply to estuarine  and
                    marine animals as discussed in (l.b.) above.  Therefore, the
                    chronic  estuarine/marine studies for HPMTS  are  not
                    required.

       c.     Toxicity to Plants

             Terrestrial and aquatic plant testing are currently not required, in
       most cases, for industrial microbiocides, including HPMTS.

2.     Environmental Fate

       a.     Environmental Fate Assessment

             Due to the current use patterns for HPMTS, the Agency requires
       only a hydrolysis study for the reregistration target data base.

       b.     Environmental Fate and Transport

             (1)    Degradation

             Hydrolysis

                    [2-14C]2-hydroxypropyl methanethiosulfonate, at 101 mg/L,
             hydrolyzed with half-lives of > 30 days at pH 5, 8.5-9.9 hours at
             pH 7, and 5.4-6.1 minutes at pH 9 in sterile  aqueous buffered
             solutions  at 25°C in the  dark for  up to 30 days.  Two major
             degradates were observed.

                    One  degradate, di-(2-hydroxyisopropyl)disulfide, was  a
             maximum of 24-29% of the recovered at 20 or 30  days in the pH
             5  solution; 61-64% of the recovered at  24.5 hours  in the pH  7
             solution;  and 63-66%  at 15.0-15.2 minutes in the  pH 9 solution.
             The other major degradate, di-(2-hydroxypropyl) disulfide, was a
             maximum of 5.9% of the recovered at  22-30 days  in the pH  5
             solution;  10-12% at 24.5 hours in the pH 7 solution; and 8.17% at
             10.1-15.2 minutes in the pH 9 solution. This study was found to be
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                           acceptable and satisfies all data requirements for HPMTS. (MRID
                           41475207)

              3.     Exposure and Risk Characterization

                    The Agency requires only a limited set of ecotoxicology and environmental
              fate studies for microbicides. HPMTS is slightly to moderately toxic to birds and
              aquatic invertebrates. While the hazard to aquatic organisms from HPMTS has
              been characterized, a quantitative risk assessment has not been conducted.   The
              risks to aquatic environments from its industrial aquatic uses are regulated under
              the NPDES permitting program of EPA's Office of Water.  The Agency currently
              requires that labels for all  HPMTS products  require that discharges to aquatic
              environments comply with an NPDES permit.

IV.    RISK MANAGEMENT AND REREGISTRATION DECISION

       A.     Determination of Eligibility

              Section 4(g)(2)(A) of  FIFRA calls for the Agency to determine,  after submission
       of relevant data concerning an active ingredient, whether products containing the active
       ingredient are eligible  for reregistration.   The Agency has previously identified and
       required the submission of the generic  (i.e. active  ingredient specific) data required to
       support reregistration of products containing the active ingredient HPMTS.  The Agency
       has completed its review  of these generic data,  and  has determined that the data are
       sufficient  to support reregistration of all  products containing HPMTS.   Appendix B
       identifies  the generic  data  requirements  that the Agency  reviewed as  part of its
       determination of reregistration eligibility of HPMTS, and lists the submitted studies that
       the Agency found acceptable.

              The data identified in Appendix B were sufficient to allow the Agency to assess the
       registered uses of HPMTS and to determine that HPMTS can be used without resulting
       in unreasonable adverse effects  to humans  and the environment.  The Agency therefore
       finds that all products containing HPMTS as the active ingredient, and as specified in this
       document, are eligible for reregistration.   The reregistration of particular products is
       addressed  in Section V  of this document.

              The Agency made its reregistration eligibility determination based upon the target
       data  base  required for  reregistration, the current guidelines for  conducting acceptable
       studies to generate such data, published scientific  literature, and the data identified in
       Appendix  B.  Although the  Agency has found that all uses of HPMTS are eligible for
       reregistration, it should be understood that the Agency may take appropriate regulatory
       action, and/or require  the submission of additional data to support the registration of
       products containing HPMTS,  if new information comes to the Agency's attention or if the
       data requirements for registration (or the guidelines for generating such data) change.


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B.     Determination of Eligibility Decision

       1.      Eligibility Decision

              Based on the reviews of the generic data for the active ingredient HPMTS,
       the Agency has sufficient information on the health effects of HPMTS and on its
       potential for causing adverse effects in fish and wildlife and the environment. The
       Agency has determined that HPMTS products, labeled and used as specified in this
       Reregistration  Eligibility Decision,  will not pose unreasonable risks or adverse
       effects to humans or the environment.   Therefore, the Agency concludes that
       products  containing HPMTS for all  uses are eligible for reregistration.

       2.      Eligible and Ineligible Uses

              The Agency has determined that all uses of HPMTS, as specified in this
       document, are eligible for reregistration.

       3.      Endangered Species Protection

              Currently,  the Agency is developing a program ("The Endangered Species
       Protection Program") to identify all pesticides whose use may cause  adverse
       impacts  on  endangered  and threatened  species and  to  implement mitigation
       measures that will  eliminate the adverse impacts.  The program would require use
       restrictions to  protect endangered and threatened species at the county  level.
       Consultations with the Fish and Wildlife Service may be necessary to assess risks
       to newly listed species or from proposed new uses. In the future, the Agency plans
       to publish a description of the Endangered Species Program in the Federal Register
       and have available voluntary county-specific bulletins.  Because the Agency is
       taking this approach for protecting  endangered and threatened species, it is not
       imposing label modifications at this time through  the  RED.   Rather, any
       requirements for  product use modifications will occur in the future under the
       Endangered Species Protection Program.

C.     Regulatory Position

       The following is a summary of the regulatory positions and rationales for HPMTS.
Where labeling revisions are imposed, specific language is set forth in Section V of this
document.

       1.      Risk Mitigation Measures/  Labeling Rationale

       Minimum (baseline) PPE requirements
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       If EPA has no special concerns about the acute effects of other adverse
effects of an active ingredient, the PPE for pesticide handlers will be based on the
acute toxicity of the end-use product.  For occupational-use products, PPE must
be established  using the process described in PR Notice 93-7 or more  recent
guidelines.

       If EPA has special concerns about an active ingredient due to very high
acute toxicity or to certain other adverse effects, such as allergic effects or delayed
effects (cancer, developmental toxicity, reproductive effects, etc.):

       •      In the RED for that active ingredient, EPA may establish minimum
              or "baseline" handler PPE requirements that pertain to all or most
              end-use products containing that active ingredient.
       •      These minimum PPE requirements must be compared with the PPE
              that would be designated on the basis of the acute toxicity of the
              end-use product.
       •      The more stringent choice for each type of PPE (i.e., bodywear,
              hand protection, footwear, eyewear, etc.)  must be placed  on the
              label of the end-use product.

Occupational-Use Products

       Primary Occupational Handlers:  EPA has determined that regulatory
action regarding the  establishment  of  active-ingredient-based minimum PPE
requirements for occupational handlers must be taken for HPMTS.  EPA notes that
HPMTS has the potential to cause severe (corrosive) effects to the skin and eyes
and is a dermal sensitizer. No traditional risk assessment needs to be performed
to assess risks due to corrosiveness and sensitization. However, EPA believes that
primary occupational handlers who are exposed to concentrated end-use products
should wear PPE in addition to the baseline long-sleeve shirt, long pants,  shoes,
and  socks.  Therefore,  EPA is  requiring the use of chemical-resistant gloves,
chemical-resistant apron, and face shield for such handlers.

       Secondary Occupational Handlers: At this time, EPA believes that risks
from skin/eye  corrosiveness  and dermal sensitization would be acceptable for
secondary occupational handlers, since the  HPMTS in such products as paints and
adhesives is very diluted, usually far  less  than one percent.

Homeowner-Use Products

       Primary Homeowner Handlers:  All HPMTS end-use pesticide products
are intended primarily for occupational use.
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                    Secondary Homeowner Handlers: At this time, EPA believes that risks
             from inhalation exposures and skin/eye corrosiveness would be acceptable for
             adhesives, metal-cutting fluids, wood products, and textiles is very diluted, usually
             far less than one percent.

             2.     Entry Restrictions

                    EPA is not establishing entry restrictions for end-use products containing
             HPMTS because the use pattern scenarios are not likely to result in significant
             human exposure to HPMTS.

             3.     Addition and Retention of Other Label Statements

                    The Agency believes it is prudent to require additional use precautions to
             afford product users increased protection from unnecessary exposure to HPMTS.
             For  similar reasons the Agency is retaining current worker and environmental
             restrictions and precautions for risk reduction. Also, all products must have their
             labels improved with adequate and specific directions for use including application
             methods, equipment, timing, and  rates. These label requirements are specified
             below in Section V.

V.     ACTIONS  REQUIRED OF REGISTRANTS

       This section specifies the data requirements and responses necessary for the reregistration
of both manufacturing-use and end-use products.

       A.    Manufacturing-Use Products

             1.     Additional Generic Data Requirements

                    The generic data base supporting the reregistration of HPMTS for the
             above eligible uses has been reviewed and determined to be substantially complete.
             No additional generic  data  are required  at this time.   The registrant is in the
             process of performing an avian acute oral study to confirm the potential hazards
             to avian species.  The study is due for  submission to the Agency by August 19,
             1996.

             2.     Labeling Requirements for Manufacturing-Use Products

                    To remain  in compliance with FIFRA, manufacturing-use product (MP)
             labeling must be revised to comply with all current EPA regulations, PR Notices
             and applicable policies.  The MP labeling must bear the following statement under
             Directions for Use:
                                          17

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              "Only for formulation into a microbiocide/microbiostat, bacteriostat for the
              following  uses:  Commercial/Industrial  Recirculating  Water  Cooling
              Systems, Industrial  Processing Water,  Pulp/Paper Mill  Water Systems,
              Industrial Coatings,  Resin/Latex/Polymer Emulsions, Latex/Oil/Varnish
              Paints,  and Wet-End Additives/Industrial Processing Chemicals."

              An MP registrant may, at his/her discretion, add one of the following
       statements to an MP label under "Directions for Use" to permit the reformulation
       of the product for a specific use or all additional uses supported by a formulator
       or user group:

              (a)     "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)."

              (b)     "This product may be used to formulate products for any additional
              use(s) not listed on the MP label if the formulator or user group has
              complied with U.S. EPA submission requirements regarding support of
              such use(s)."

                           Effluent Discharge Labeling Statements

              "Do not use in facilities discharging directly or indirectly to the estuarine
              or marine environment."

                    To reduce environmental risk from HPMTS discharge and disposal,
              product labels must include the statements pertaining to effluent discharge
              under the NPDES  permitting system  (refer  to  PR  Notice 93-10)  and
              disposal under  any applicable federal laws after the above statement.

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 product specific data requirements are listed in Appendix G, the
       Product Specific Data Call-In Notice.

              Registrants must review previous data submissions to ensure that they meet
       current EPA acceptance criteria (Appendix F; Attachment E) and if not, commit
       to conduct new studies.  If a  registrant believes that previously submitted data meet
       current testing standards, then study MRID numbers should be cited according to


                                    18

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the instructions in the Requirement Status and Registrants Response Form provided
for each product.

2.     Labeling Requirements for End-Use Products

       a.     Occupational  Labeling  PPE  Requirements  for  Pesticide
       Handlers

             Sole-active-ingredient end-use  products that contain HPMTS must
       be revised to remove any conflicting PPE requirements on their current
       labeling.

             Multiple-active-ingredient end-use products that contain HPMTS
       must compare the handler personal protective equipment requirements set
       forth in this section to the PPE requirements on their current labeling and
       retain the more  protective. For guidance on which PPE is considered more
       protective, see  PR Notice 93-7.

             The PPE for each HPMTS occupational end-use product must be
       established based on the acute toxicity of each end-use product. If the end-
       use product is classified as toxicity category I or II for acute eye irritation
       potential (or the eye  irritation  study is waived due  to corrosiveness),
       protective eyewear must be required  for all handlers of HPMTS.  If the
       end-use product is classified as toxicity category I or II for acute skin
       irritation  potential  (or  the skin  irritation  study  is  waived  due  to
       corrosiveness),  chemical-resistant gloves and a chemical-resistant apron
       must be required for all handlers of HPMTS.

             Minimum  (Baseline) PPE/Engineering Control Requirements
             for Products Intended Primarily for Occupational Use

                    The  minimum  (baseline)  PPE for occupational  uses  of
             HPMTS end-use products is:

                    "Mixers, loaders,  and others exposed  to  the concentrate
                    must wear:
                    —Long-sleeve shirt and long pants,
                    —Chemical-resistant gloves*,
                    —shoes plus socks,
                    —chemical-resistant apron, and
                    —face shield."

             * For the glove statement, use the statement established for HPMTS
             through the instructions in Supplement Three of PR Notice 93-7.

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       However, the corrosiveness and penetration of HPMTS itself must
       be considered and appropriate chemical-resistant materials must be
       listed.

Placement in Labeling

       The personal protective equipment language must be placed on the
end-use product labeling in the location specified in PR Notice 93-7 and the
format and language  of  the  PPE requirements must be  the same as  is
specified in PR Notice 93-7.

b.     Other Label Requirements

       The Agency is requiring the following labeling statements to be
located on all end-use products containing HPMTS.

       (1)    Directions for use

             Registrants must specify on labeling the  complete directions
       for use for each use pattern: site of application,  type of application,
       timing of application, equipment used for application, and the rate
       of application (dosage).

       (2)    Application restrictions

       "Do not use this product in a way that will contact workers
       or other persons."

       (3)    Skin sensitizer statement

       "This product may  cause skin  sensitization reactions  in some
       people."

       (4)    User safety recommendations

             For all HPMTS end-use products:

       "Users should wash hands before eating, drinking, chewing gum,
       using tobacco, or using the toilet."

       "Users should remove clothing immediately if pesticide gets inside.
       Then wash thoroughly and put on clean clothing."

       For HPMTS end-use products "gloves" if gloves are required PPE:

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                    "Users should remove Personal Protective Equipment immediately
                    after handling  this product.  Wash the outside of gloves before
                    removing.  As soon as possible, wash thoroughly."

                    (5)    Effluent Discharge Labeling Statements

                           Refer to subsection A. above for labeling requirements for
                    effluent discharge.

C.     Existing Stocks

       Registrants may generally distribute and sell products bearing  old labels/labeling
for 26 months from the date of the issuance of this Reregistration Eligibility Decision
(RED). Persons other than the registrant may generally distribute or sell such products for
50 months from the date  of the issuance of this RED.  However, 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. Refer to "Existing Stocks of Pesticide
Products;  Statement of Policy"; Federal Register, Volume 56, No. 123, June 26, 1991.

       The Agency has determined that registrants may distribute and sell hydroxypropyl
methanethiosulfonate products bearing old labels/labeling for 26 months from the date of
issuance of this RED.  Persons other than the registrant may distribute  or sell such
products for 50 months from the  date of the issuance  of this RED.  Registrants and
persons other than registrants remain obligated to meet pre-existing Agency imposed label
changes and existing stocks requirements applicable to products they sell or distribute.
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VI. APPENDICES

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                                      Case 3033[Busan 74  (*)]
                                APPENDIX A

                                       Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                                          Form(s
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
Min.  Appl.       Max.  Appl.  Soil Max. # Apps Max. Dose  [(AI   Min.  Restr.      Geographic  Limitations       Use
Rate  (AI un-      Rate  (AI Tex. @ Max. Rate unless  noted     Interv Entry    Allowed           Disallowed   Limitations
less noted    unless noted Max. /crop /year otherwise)/A]    (days) Interv                                  Codes
otherwise)       otherwise)  Dose cycle       /crop    /year          [day(s)]
                                            cycle
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED
Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
Water treatment  (recirculating system),
Intermittent  (slug) (initial), Not on
label, Not Applicable, Not applicable for
this use
Water treatment  (recirculating system),
Intermittent  (slug)(subsequent), Not on
label, Not Applicable, Not applicable for
this use
EMULSIONS, RESIN/LATEX/POLYMER

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
                                                   W 2.1

                                                   W 2.1

                                                   W .4
                                                                       W  4000    *   NS     NS          NS       NS    NS

                                                                       W  4050    *   NS     NS          NS       NS    NS

                                                                          Use Group:  AQUATIC  NON-FOOD INDUSTRIAL

                                                                        W 8 . 1    *   NS     NS          NS       NS    NS
                     W 8 . 3   *  NS    NS         NS

                     W 8 . 5   *  NS    NS         NS

                      Use Group: INDOOR NON-FOOD

                    W 4000   *  NS    NS         NS
                                                                                        25

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                                      Report  Run Date:  11/22/95
                                      PRD  Report Date:  04/18/95
                                      Case 3033[Busan 74  (*)]
)   Time 10:53
                                                      LUIS 2.2 - Page:
                                                                                APPENDIX A REPORT
                                                                                          Chemical  035604[S-(2-Hydroxypropyl)  thiomethanes]
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
                                        /year
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED (con't)
PAINTS, LATEX/OIL/VARNISH  (APPLIED FILM)

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
PULP/PAPER MILL WATER SYSTEMS

Water treatment, Not on label, Not on     SC/L
label, Not Applicable, Not applicable for
this use

                                          SC/L

                                          SC/L

                                          SC/L

                                          SC/L

WET-END ADDITIVES/INDUSTRIAL PROCESSING CHEMICALS

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
        W 4 .2    *   NS     NS          NS

        W 4 . 3    *   NS     NS          NS

         Use Group:  INDOOR NON-FOOD

       W 2800    *   NS     NS          NS
          W 4    *   NS     NS          NS

          W 4    *   NS     NS          NS

       W 4.05    *   NS     NS          NS

        W 281    *   NS     NS          NS

         Use Group:  INDOOR NON-FOOD

       W 4000    *   NS     NS          NS
                                                                                        26

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                                      Report Run Date:  11/22/95
                                      PRD Report Date:  04/18/95
                                      Case 3033[Busan 74  (*)]
              )   Time 10:53
                                                                               Page:
                                                                                APPENDIX A REPORT
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only)  & Effica-
  cy Influencing Factor  (Antimicrobial only)
Min. Appl.
Rate  (AI un-
less noted
otherwise)
                         Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                        4444444444444444444444^
  Max.  Appl.  Soil Max.  # Apps Max. Dose  [(AI   Min.  Restr.
    Rate  (AI Tex. @ Max. Rate unless noted     Interv Entry
unless noted Max. /crop /year otherwise)/A]    (days) Interv
  otherwise)  Dose cycle       /crop    /year          [day(s)
                              cycle
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED  (con't)
WET-END ADDITIVES/INDUSTRIAL PROCESSING CHEMICALS  (con't)

                                           SC/L     W  400

                                           SC/L     W  405
                      Use Group: INDOOR NON-FOOD  (con't)

                    W 4000   *  NS    NS          NS       NS    NS      NS

                    W 4050   *  NS    NS          NS       NS    NS      NS
                                                                                        27

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                                      Report  Run Date:  11/22/95  )   Time 10:53                                         LUIS 2.2 - Page:    4
                                      PRD  Report Date:  04/18/95
                                                                                APPENDIX A REPORT

                                      Case 3033[Busan 74  (*)]                             Chemical  035604[S-(2-Hydroxypropyl)  thiomethanes]
LEGEND
444444
  HEADER ABBREVIATIONS
  Min .  Appl .  Rate (AI unless :  Minimum dose for a single application to a single  site.   System  calculated.  Microbial  claims  only.
  noted otherwise)
  Max .  Appl .  Rate (AI unless :  Maximum dose for a single application to a single  site.   System  calculated.
  noted otherwise)
                             :  Maximum dose for a single application to a single  site as  related  to  soil  texture  (Herbicide claims  only) .
                             :  Maximum number of Applications at Maximum Dosage Rate.   Example: "4 applications per  year"  is  expressed as  "4/1  yr";  "4  applications per 3
                               years" is expressed as "4/3 yr"
                             :  Maximum dose applied to a site over a single crop  cycle  or year.   System calculated.
                               Minimum Interval between Applications  (days)
                 terv  (days) :
  PRD Report Date            :



  SOIL TEXTURE FOR MAX APP. RATE
  *       :  Non-specific
  C       :  Coarse
  M       :  Medium
  F       :  Fine
  O       :  Others

  FORMULATION CODES
  SC/L    :  SOLUBLE CONCENTRATE/LIQUID

  ABBREVIATIONS
          :  As Needed
          :  Not Applicable
          :  Not Specified  (on label)
          :  Unconverted due to lack of data  (on label), or with one of following units: bag, bait,  bait  block,  bait  pack,  bait  station,  bait station (s),  block,  briquet,
            briquets, bursts, cake, can, canister, capsule, cartridges, coil, collar, container,  dispenser,  drop,  eartag,  grains,  lure,  pack,  packet,  packets,  pad,  part,
            parts, pellets, piece, pieces, pill, pumps, sec, sec burst, sheet,  spike, stake, stick,  strip,  tab,  tablet,  tablets,  tag,  tape,  towelette,  tray,  unit,  --


  APPLICATION RATE
          :  Dosage Can Not be Calculated
          :  No Calculation can be made
          :  PPM calculated by weight
          :  PPM Calculated by volume
          :  Unknown whether PPM is given by weight or by volume
          :  Hundred Weight
  nnE-xx  :  nn times  (10 power -xx) ; for instance,  "1.234E-04" is equivalent to ".0001234"

  USE LIMITATIONS CODES
  A08 :  Preclean claim.
                                                                                        28

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                                   Report Run  Date:  11/22/95   )   Time 10:53                                          LUIS 2.2 - Page:    5
                                   PRO Report  Date:  04/18/95
                                                                              APPENDIX A REPORT

                                    Case 3033[Busan 74  (*)]                             Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                              444444
USE LIMITATIONS CODES (Cont.)
C18 :  Do not discharge effluent containing this pesticide  into sewage systems without  notifying the sewage treatment plant  authority (POTW).
023 :  NPDES license restriction.
024 :  Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans,  or public water.   (NPDES  license  restriction)
CAH :  Do not discharge into lakes, streams,  ponds, or public water unless in accordance with NPDES Permit.
CAL :  Do not contaminate water, food or feed.
* NUMBER IN PARENTHESES REPRESENTS THE NUMBER OF TIME UNITS (HOURS,DAYS, ETC.) DESCRIBED IN THE LIMITATION.
                                                                                     29

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                               GUIDE TO APPENDIX B
Appendix B contains listings of data requirements which support the reregistration for active
ingredients within the case Hydroxypropyl methanethiosulfonate covered by this Reregistration
Eligibility Decision Document. It contains generic data requirements that apply to Hydroxypropyl
methanethiosulfonate  in all  products,  including  data  requirements for which a  "typical
formulation" is the test substance.

       The data table is organized in the following format:

       1.  Data Requirement (Column 1). The data requirements are listed in the order in which
they appear in 40 CFR Part 158.  the reference numbers accompanying each test refer to the test
protocols set in  the Pesticide Assessment Guidelines, which  are available from  the National
Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703) 487-4650.

       2.  Use Pattern (Column 2). This column indicates the use patterns for which the data
requirements apply. The following letter designations are used for the given use patterns:

                           A     Terrestrial food
                           B     Terrestrial feed
                           C     Terrestrial non-food
                           D     Aquatic food
                           E     Aquatic non-food outdoor
                           F     Aquatic non-food industrial
                           G     Aquatic non-food residential
                           H     Greenhouse food
                           I      Greenhouse non-food
                           J      Forestry
                           K     Residential
                           L     Indoor food
                           M     Indoor non-food
                           N     Indoor medical
                           0     Indoor residential

       3.  Bibliographic citation  (Column 3).  If the Agency has acceptable data in its files, this
column lists the identifying number  of each study.   This normally is the Master  Record
Identification  (MRID)  number,  but may be a "GS" number  if no  MRID number has been
assigned.  Refer  to the  Bibliography appendix for a complete citation of the study.
                                          30

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                    APPENDIX B
Data Supporting Guideline Requirements for the Reregistration of HPMTS
REQUIREMENT
USE PATTERN CITATION(S)
PRODUCT CHEMISTRY
61-1
61-2A
61-2B
62-1
62-2
62-3
63-2
63-3
63-4
63-6
63-7
63-8
63-9
63-12
63-13
63-17
63-20
Chemical Identity
Start. Mat. & Mnfg. Process
Formation of Impurities
Preliminary Analysis
Certification of limits
Analytical Method
Color
Physical State
Odor
Boiling Point
Density
Solubility
Vapor Pressure
PH
Stability
Storage stability
Corrosion characteristics
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M

43420501
43420501
41680902

41680902
41680903
41608903
41680903
41680903
41680903
43420101
42287901
41680903

42766601
42766601
                            31

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         Data Supporting Guideline Requirements for the Reregistration of HPMTS
REQUIREMENT USE PATTERN CITATION(S)
ECOLOGICAL EFFECTS
71-1A
71-2A
71-2B
72-1A
72-1C
72-2A
Acute Avian Oral - Quail/Duck
Avian Dietary - Quail
Avian Dietary - Duck
Fish Toxicity Bluegill
Fish Toxicity Rainbow Trout
Invertebrate Toxicity
F
F
F
F
F
F

41629801, 126121, 126122
249523
41733201
41733203
41733202
TOXICOLOGY
81-1
81-2
81-6
82-3
83-3A
83-3B
84-2A
84-2B
84-4
Acute Oral Toxicity - Rat
Acute Dermal Toxicity - Rabbit/Rat
Dermal Sensitization - Guinea Pig
90-Day Dermal - Rodent
Developmental Toxicity - Rat
Developmental Toxicity - Rabbit
Gene Mutation (Ames Test)
Structural Chromosomal Aberration
Other Genotoxic Effects
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
41634701
41632401
42349201
40974701
41010501
41010401
40229601
40420201
40420202
OCCUPATIONAL/RESIDENTIAL EXPOSURE
None
Required
                                              32

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	Data Supporting Guideline Requirements for the Reregistration of HPMTS	
 REQUIREMENT                                USE PATTERN                CITATION(S)
 ENVIRONMENTAL FATE
 160-5     Chemical Identity	F,M	43420501	
 161-1     Hydrolysis                                 F        42771801
 RESIDUE CHEMISTRY
 None	Required	
                                           33

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Page Intentionally Blank
              34

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                               GUIDE TO APPENDIX C

1.      CONTENTS OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
       considered relevant by EPA in arriving at the positions and conclusions stated
       elsewhere in the Reregistration Eligibility Document. Primary sources for studies in
       this bibliography have been the body of data submitted to EPA and its predecessor
       agencies in support of past regulatory decisions. Selections from other sources
       including the published literature, in those instances where they have been considered,
       are included.

2.      UNITS OF ENTRY. The unit of entry in this bibliography is called a "study".  In the
       case of published materials, this corresponds closely to an article. In the case of
       unpublished materials submitted to the Agency, the Agency has sought to identify
       documents at a level parallel to the published article from within the typically larger
       volumes in which they were submitted. The resulting "studies" generally have a
       distinct title (or at least a single subject), can stand alone for purposes of review and
       can be described with a conventional bibliographic citation.  The Agency has also
       attempted to  unite basic documents and commentaries upon them, treating them  as a
       single study.

3.      IDENTIFICATION OF ENTRIES.  The entries in this bibliography are sorted
       numerically by Master Record Identifier, or "MRID number".  This number is unique
       to the citation,  and should be used whenever a specific reference is required.  It is not
       related  to the six-digit "Accession Number" which has been used to identify volumes of
       submitted studies (see paragraph 4 (d) (4) below for further explanation).  In a few
       cases, entries added to the bibliography late in the review may be preceded by a nine
       character temporary identifier. These  entries are listed after all MRID entries.  This
       temporary identifying number is also to be used whenever specific reference is needed.

4.      FORM OF ENTRY. In addition to the Master Record Identifier (MRID), each entry
       consists of a citation containing standard elements followed,  in the case of material
       submitted to  EPA, by a description of the earliest known submission.  Bibliographic
       conventions used reflect the standard of the American National Standards Institute
       (ANSI), expanded to provide for certain special needs.

       a     Author.  Whenever the author could confidently be identified, the Agency has
             chosen to show a personal author.  When no individual was identified, the
             Agency has shown an identifiable laboratory or testing facility as the  author.
             When no author or laboratory could be identified, the Agency has shown the
             first submitter as the author.

       b.     Document date.  The date of the study is taken directly from the document.
             When the date is followed by a question mark, the bibliographer has deduced
             the date from the evidence contained in the document.  When the date appears
             as (19??), the Agency was unable to determine or estimate the date of the
             document.

                                           35

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c.      Title.  In some cases, it has been necessary for the Agency bibliographers to
       create or enhance a document title.  Any such editorial insertions are contained
       between square brackets.

d.      Trailing parentheses. For studies submitted to the Agency in the past, the
       trailing parentheses include (in addition to any self-explanatory text) the
       following elements describing the earliest known submission:

       (1)    Submission date.  The date of the earliest known submission appears
             immediately following the word "received."

       (2)    Administrative number.   The next element immediately following the
             word "under" is the registration number,  experimental use permit
             number, petition number, or other administrative number associated
             with the earliest known submission.

       (3)    Submitter.  The third  element is the submitter. When authorship is
             defaulted to the submitter, this element is omitted.

       (4)    Volume Identification (Accession Numbers).  The final element in the
             trailing parentheses identifies the EPA accession number of the volume
             in which the original submission of the study appears.  The six-digit
             accession number follows the symbol "CDL," which stands for
             "Company Data Library."  This accession number is in turn followed by
             an alphabetic suffix which shows the relative position of the study within
             the volume.
                                    36

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                               BIBLIOGRAPHY
MRID
CITATION
00126120     Hazleton Raltech, Inc. (1982) Avian Single-dose Oral LD50: Mallard Duck (Anas
             platyrhynchos): Study No. 6026-119.  Final rept. (Unpublished study received Feb
             15,  1983 under 1448-78; submitted by Buckman Laboratories, Inc., Memphis,
             TN; CDL:249523-B)

00126121     Hazleton Raltech, Inc.  (1982) Avian  Dietary LC50: Bobwhite Quail (Colinus
             virginianus): Study No. 6026-121. Final rept.  (Unpublished study received Feb
             15,  1983 under 1448-78; submitted by Buckman Laboratories, Inc., Memphis,
             TN; CDL:249523-C)

00126122     Hazleton Raltech,  Inc.  (1982)  Avian Dietary LC50:  Mallard Duck (Anas
             platyrhynchos): Study No. 6026-120. (Unpublished study received Feb 15, 1983
             under  1448-78;  submitted  by Buckman Laboratories,  Inc.,  Memphis, TN;
             CDL:249523-D)

40229601     Jagannath,   D.R.  [1987]   "Mutagenicity Test  on  HPMTS in  the  Ames
             Salmonella/Microsome Reverse Mutation  Assay", [HLA 9786-0-401];  Hazleton
             Laboratories America, Inc., Kensington, MD; [HED Doc. No. 010670].

40420201     Murli, H. [1987]  "Mutagenicity Test on HPMTS in an In Vitro Sister Chromatid
             Exchange (SCE) Assay Measuring Sister Chromatid Exchange Frequencies in
             Chinese Hamster Ovary (CHO)  Cells", [HLA 9973-0-438]; Hazleton Laboratories
             America, Inc., Kensington, MD; [HED Doc. No.  006594].

40420202     Cifone,  M.A.  [1987]  "Mutagenicity Test on HPMTS in the  Rat Primary
             Hepatocyte Unscheduled DNA Synthesis Assay",  [HLA  9973-0-447];  Hazleton
             Laboratories America, Inc., Kensington, MD; [HED Doc. No. 006594].

40747101     Rodwell, D.E.  [1988]  "Pilot  Teratology Study in Rats with HPMTS",  [SLS
             3138.10]];  Springborn Life Sciences,  Inc.; Spencerville,  OH; [HED Doc. No.
             006920].

40747102     Siglin, J.C. [1988] "Two-Week  Dermal Toxicity  Study in Rats with HPMTS",
             [SLS 3138.8]; Springborn Life Sciences, Inc., Spencerville, OH; [HED Doc. No.
             006920].

40974701     Siglin, J.C., [1988] "91-Day Dermal Toxicity Study in Rats with HPMTS", [SLS
             3138.9]; Springborn Life Sciences, Inc., Spencerville,  OH;  [HED Doc.  No.
             007483].
                                        37

-------
                               BIBLIOGRAPHY
MRID
CITATION
41010401     Rodwell,  D.E.  [1988]  "Teratology Study  in  Rabbits with HPMTS",  [SLS
             3138.13]; Springborn Life Sciences, Inc., Spencerville,  OH; [HED Doc.  No.
             007453].

41010501     Rodwell,  D.E. [1988] "Pilot Teratology Study in Rabbits with HPMTS",  [SLS
             3138.12], Springborn Life Sciences, Inc., Spencerville,  OH; [HED Doc.  No.
             006984].

41010501     Rodwell, D.E. [1988] "Teratology Study in Rats with HPMTS",  [SLS 3138.11];
             Springborn Life Sciences, Inc., Spencerville, OH;  [HED Doc. No. 007453].

41632401     Glaza, S. M.  [1990] "Acute Dermal Toxicity of HPMTS in Rabbits", [HLA 0060-
             5-263]; Hazleton Laboratories America, Inc.,  Madison,  WI; [HED Doc.  No.
             010670].

41634701     Glaza, S. M.  [1990] "Acute Oral Toxicity of HPMTS in Rats" [HLA 0060-5-262];
             Hazleton Laboratories America, Inc., Madison, WI; [HED Doc. No. 010670].

41733201     Ward,  G. (1990) 2-Hydrocypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to Bluegill, Lepomis macrochirus, Under Flow-through Test Conditions:
             Lab Project  Number: J9007018C.   Unpublished study  prepared by  Toxikon
             Environmental Sciences.  37 p.

41733202     Ward,  G. (1990) 2-Hydroxypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to the Water Flea, Daphnia magna, under Flow-through Test Conditions:
             Lab Project  Number: J9007018B.   Unpublished study  prepared by  Toxikon
             Environmental Sciences.  38 p.

41733203     Ward,  G. (1990) 2-Hydroxypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to Rainbow Trout,  Oncorhynchus mykiss,  under Flowthrough Test
             Conditions: Lab Project Number: J9007018D.   Unpublished study prepared by
             Toxikon Environmental Sciences. 38 p.

42349201     Karcher,  R.,  Siglin,  J.C.   and  Becci,   P.C.   [1986]  "Delayed  Contact
             Hypersensitivity Study in Guinea Pigs with HPMTS", [SIB 3138.7]; Springborn
             Institute for Bioresearch, Inc., Spencerville, OH; [HED Doc. No. 009690].

42771801     Mao, J. (1993) HPMTS-Determination of Aqueous Hydrolysis Rate Constants and
             Half-Lives: Lab Project Number: 995.0292.6138.715: 93-3-4668.  Unpublished
             study prepared by Springborn Labs, Inc. 76  p.
                                        38

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                               BIBLIOGRAPHY

MRID                        CITATION
            Doyle,  E.  [1995]   "Less  than  Lifetime/Peer  Review  Report of  [S-(2-
            hydroxypropyl)thiomethane sulfonate]", Internal U.S. EPA memorandum, [Doyle
            to Aikens].

            Ghali,   G.Z.  [1995]  "RfD/Peer  Review  Report  of  Busan  74  [S-(2-
            hydroxypropyl)thiomethane sulfonate]", Internal U.S. EPA memorandum, [Ghali
            to Swindell,  2/15/95].

            Whalan, J.E., "Policy on Acute Inhalation Toxicity Data Waivers", Internal U.S.
            EPA memo,  Nov. 27, 1991 [Fenner-Crisp to Lindsay], 12/8/91.
DRAFT:EPA:OPP:HED:RCAB:AMAikens: 8/18/95: Revised (TOX 81-3) 8/22/95: Revised
(TOX CATEGORY 81-4  and 81-5; addition of OREB  provisional statements/ contractor)
8/29/95: Edited/RCAB 8/31/95: Final for OD review 9/5/95: Edited  9/15/95: Edited to include
OREB/S. McDonald comments received this date 9/19/95: Revised 9/22/95.
                                       39

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                      BIBLIOGRAPHY




MRID                 CITATION
                            40

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                      WASHINGTON, D.C.  20460
                                                                           OFFICE OF
                                                                     PREVENTION, PESTICIDES
                                                                     AND TOXIC SUBSTANCES
                               DATA CALL-IN NOTICE
CERTIFIED MAIL
Dear Sir or Madam:
This Notice requires you and other registrants of pesticide products containing the active
ingredient identified in Attachment 1 of this Notice, the Data Call-in Chemical Status Sheet, to
submit certain product specific data as noted herein to the U.S. Environmental Protection
Agency (EPA, the Agency).  These data are necessary to maintain the continued registration of
your product(s)  containing this active ingredient.  Within 90 days after you receive this Notice
you must respond as set forth in Section III  below.  Your response must state:

       1.     How you will comply with the requirements set forth in this Notice and its
             Attachments 1 through 6;  or

       2.     Why you believe you are exempt from the requirements listed in this Notice and
             in Attachment 3, Requirements  Status and Registrant's Response Form, (see
             section III-B);  or

       3.     Why you believe EPA should not require your submission  of product specific
             data in the manner specified by this Notice (see section III-D).

       If you do not respond to this Notice, or if you do not satisfy EPA that you will comply
with its requirements or should be exempt or excused from doing so, then the registration of


                                          41

-------
your product(s) subject to this Notice will be subject to suspension.  We have provided a list of
all of your products subject to this Notice in Attachment 2, Data Call-In Response Form, as
well as a list of all registrants who were sent this Notice (Attachment 6).

       The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide
and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B).  Collection of this
information is  authorized under the Paperwork Reduction Act by OMB Approval No. 2070-
0107 and 2070-0057 (expiration date 03-31-96).

       This Notice is divided into six sections and six Attachments. The Notice itself contains
information and instructions applicable to all Data Call-in  Notices. The Attachments contain
specific chemical information and instructions. The six sections of the Notice are:

       Section I  -  Why You Are Receiving This Notice
       Section II  -   Data Required By This Notice
       Section III -   Compliance With  Requirements Of This Notice
       Section IV -   Consequences Of  Failure To  Comply With This Notice
       Section V  -   Registrants'  Obligation To  Report Possible Unreasonable Adverse
                    Effects
       Section VI -   Inquiries And Responses To This  Notice

The Attachments to this Notice are:

       1 -    Data Call-In Chemical Status Sheet
       2 -    Product-Specific Data Call-In Response Form
       3 -    Requirements Status and Registrant's Response Form
       4 -    EPA Batching of End-Use Products for Meeting  Acute Toxicology Data
              Requirements for Reregistration
       5 -    List of Registrants  Receiving This Notice
       6 -    Cost Share and  Data Compensation Forms
SECTION I.  WHY YOU ARE RECEIVING THIS NOTICE

       The Agency has reviewed existing data for this active ingredient and reevaluated the
data needed to support continued registration of the subject active ingredient.  The Agency has
concluded that the only additional data necessary are product specific data.  No additional
generic data requirements are being imposed. You have been sent this  Notice because you
have product(s) containing the subject active ingredient.

SECTION II.  DATA REQUIRED BY THIS NOTICE

II-A.  DATA REQUIRED

       The product specific data required by this Notice are specified in Attachment 3,
Requirements Status and Registrant's Response Form.  Depending on the results of the studies
required in this Notice, additional testing may be required.

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II-B. SCHEDULE FOR SUBMISSION OF DATA

   You are required to submit the data or otherwise satisfy the data requirements specified in
Attachment 3, Requirements Status and Registrant's Response Form, within the time frames
provided.

II-C. TESTING PROTOCOL

   All studies required under this Notice must be conducted in accordance with test standards
outlined in the Pesticide Assessment Guidelines for those studies for which guidelines have been
established.

       These EPA Guidelines are available from the National Technical Information Service
(NTIS), Attn: Order Desk, 5285 Port Royal Road, Springfield, Va 22161 (tel: 703-487-4650).

       Protocols approved by the Organization for Economic Cooperation and Development
(OECD) are also acceptable if the OECD-recommended test standards conform to those specified
in the Pesticide Data Requirements regulation (40 CFR § 158.70).  When using the OECD
protocols, they should be modified as appropriate so that the data generated by the study will
satisfy  the requirements of 40 CFR § 158.  Normally,  the Agency will not extend deadlines for
complying with data requirements when the studies were not conducted in accordance with
acceptable  standards.  The OECD protocols are available from OECD, 2001 L Street, N.W.,
Washington, D.C. 20036 (Telephone number 202-785-6323;  Fax telephone number 202-785-
0350).

       All new studies and proposed protocols submitted in response to this Data Call-in Notice
must be in  accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)].

II-D. REGISTRANTS RECEIVING PREVIOUS SECTION 3(c)(2)(B) NOTICES
     ISSUED BY THE AGENCY

     Unless otherwise noted herein, this Data Call-In does not in any way supersede or change the
requirements of any previous Data Call-In(s), or any other agreements entered into with the
Agency pertaining to such prior Notice.  Registrants must comply with the  requirements of all
Notices to avoid issuance of a Notice of Intent to Suspend their affected products.

SECTION  III.  COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

III-A.  SCHEDULE FOR RESPONDING TO THE AGENCY

       The appropriate responses initially required by this Notice for product specific data must
be submitted to the Agency within 90 days after your receipt of this Notice. Failure to adequately
respond to  this Notice within 90  days of your receipt will be a basis for issuing a Notice of Intent
to Suspend (NOIS) affecting your products. This and other bases for issuance of NOIS due to
failure  to comply with this Notice are presented in Section IV-A and IV-B.

III-B. OPTIONS FOR RESPONDING TO THE AGENCY

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       The options for responding to this Notice for product specific data are:  (a) voluntary
cancellation,  (b) agree to satisfy the product specific data requirements imposed by this notice or
(c) request a data waiver (s).

       A discussion of how to respond if you chose the Voluntary Cancellation option is
presented  below. A discussion of the various options available for satisfying the product specific
data requirements of this Notice is contained in Section III-C. A discussion of options relating to
requests for data waivers is contained in Section III-D.

       There are two forms that accompany this Notice of which, depending upon your response,
one or both must be used in your response to the Agency. These  forms are the Data-Call-in
Response Form, and the Requirements  Status and Registrant's Response Form, Attachment 2 and
Attachment 3. The Data Call-in Response Form must be submitted as part of every response to
this Notice.  In addition, one copy of the Requirements Status and Registrant's Response Form
must be submitted for each product listed on the Data Call-In Response Form unless the voluntary
cancellation option is selected or unless the product is identical to another  (refer to the instructions
for completing the Data Call-In Response Form in Attachment 2). Please note that the company's
authorized representative is required  to sign the first page of the Data Call-In Response Form and
Requirements Status and Registrant's Response Form (if this form is required)  and initial any
subsequent pages. The forms contain separate detailed instructions on the response options. Do
not alter the printed material.  If you have questions or need assistance in preparing your
response,  call or write the contact person(s) identified in Attachment 1.

       1. Voluntary Cancellation - You may avoid the requirements of this Notice by requesting
voluntary  cancellation  of your product(s)  containing the active ingredient that is the subject of this
Notice. If you wish to voluntarily cancel your product, you must submit a completed Data Call-In
Response Form, indicating your election of this option.  Voluntary cancellation is item number 5
on the Data Call-In Response Form. If you choose this  option, this is the only form that you are
required to complete.

       If you chose to voluntarily cancel your  product, further sale and distribution of your
product after  the effective date of cancellation must be in accordance with  the Existing Stocks
provisions of this Notice which are contained in Section IV-C.
       2. Satisfying the Product Specific Data Requirements of this Notice  There are various
options available to satisfy the product specific data requirements of this Notice.  These options
are discussed in Section III-C of this Notice and comprise options 1 through 6 on the
Requirements Status and Registrant's Response Form and item numbers 7a  and 7b on the Data
Call-in Response Form. Deletion of a use(s) and the low volume/minor use option are not valid
options for fulfilling product specific data requirements.

       3. Request  for Product Specific Data Waivers.  Waivers for product specific  data are
discussed in Section III-D of this Notice and are covered by option 7  on the Requirements Status
and Registrant's Response Form. If you choose one of these options, you must submit both forms
as well as any other information/data pertaining to the option chosen  to address the data
requirement.

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III-C  SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

       If you acknowledge on the Data Call-In Response Form that you agree to satisfy the
product specific data requirements (i.e. you select item number 7a or 7b), then you must select
one of the six options on the Requirements Status and Registrant's Response Form related to data
production for each data requirement.  Your option selection should be entered under item
number 9,  "Registrant Response."  The six options  related to data production are the first six
options discussed under item 9 in the instructions for completing the Requirements Status and
Registrant's Response Form.  These six options are listed immediately below with information in
parentheses to guide registrants to additional instructions provided in this Section. The options
are:

       (1)     I will generate and submit data within the specified time frame (Developing Data)
       (2)     I have entered into an agreement with one or more registrants to develop data
             jointly (Cost Sharing)
       (3)     I have made offers to cost-share  (Offers to Cost Share)
       (4)     I am submitting an existing study that has not been submitted previously to the
              Agency by anyone (Submitting an Existing Study)
       (5)     I am submitting or citing data to upgrade a study classified by EPA as partially
              acceptable and upgradeable (Upgrading a Study)
       (6)     I am citing an existing study that EPA has classified as acceptable or an existing
              study that has been submitted but not reviewed by the Agency (Citing an Existing
              Study)

       Option 1, Developing Data — If you choose  to develop the required  data it must be in
conformance with Agency deadlines and with other Agency requirements as referenced herein and
in the attachments.  All data  generated and submitted must comply with the Good Laboratory
Practice (GLP) rule (40  CFR Part 160), be conducted according to the Pesticide Assessment
Guidelines (PAG), and be in conformance with the requirements of PR Notice 86-5.

       The time frames in the Requirements Status  and Registrant's Response Form are the time
frames that the Agency is allowing for the submission of completed study reports. The noted
deadlines run from the date of the receipt of this Notice by the registrant. If the data are not
submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to Suspend the
affected registration(s).

       If you cannot submit the data/reports to the Agency in the time required by this Notice and
intend to seek  additional time to meet the requirements(s), you must submit a request to the
Agency which includes:  (1)  a detailed description of the expected difficulty and (2)  a proposed
schedule including alternative dates for meeting such requirements on a step-by-step basis.  You
must explain any technical or laboratory difficulties and provide  documentation from the
laboratory performing the testing.  While EPA  is considering your request,  the original deadline
remains. The  Agency will respond to your request  in writing. If EPA does not grant your
request, the original deadline remains.  Normally, extensions can be requested  only in  cases of
extraordinary testing problems beyond the expectation or control of the registrant. Extensions
will not be given in submitting the 90-day responses.  Extensions will not be considered if the
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request for extension is not made in a timely fashion; in no event shall an extension request be
considered if it is submitted at or after the lapse of the subject deadline.

       Option 2, Agreement to Share in Cost to Develop Data  — Registrants may only choose
this option for acute toxicity data and certain efficacy data and  only if EPA has indicated in the
attached data tables that your product and at least one other product are similar for purposes of
depending on the same data.  If this is the case, data may be generated for just one of the products
in the group. The registration number of the product for which data will be submitted must be
noted in the agreement to cost share by the registrant selecting  this option. If you choose to enter
into an agreement to share in the cost of producing the required data but will not be submitting
the data yourself, you must provide the name  of the registrant who will be submitting the data.
You must also provide EPA with documentary evidence that an agreement has been formed.  Such
evidence may be your letter offering to join in an agreement and the other registrant's acceptance
of your offer, or a written statement by the parties that an agreement exists.  The agreement to
produce the data need not specify all of the terms of the final arrangement between the parties or
the mechanism  to resolve the  terms.  Section 3(c)(2)(B) provides that if the parties cannot resolve
the terms  of the agreement they may resolve their differences through binding arbitration.

       Option 3, Offer to Share  in  the Cost of Data Development — This option only applies  to
acute  toxicity and certain efficacy data as described in option 2 above.  If you have made an offer
to pay in an attempt to enter into an agreement or amend an existing agreement to meet the
requirements of this Notice and have been unsuccessful, you may request EPA (by selecting this
option) to exercise its discretion not to suspend your registration(s), although you do not comply
with the data submission requirements of this  Notice. EPA has determined that as a general
policy, absent other relevant considerations, it will not suspend the registration of a product of a
registrant who has in good  faith  sought and continues to seek to enter into a joint data
development/cost sharing program, but the  other registrant(s) developing the data has refused to
accept your offer.  To qualify for this option,  you must submit documentation to  the Agency
proving that you have made an offer to another registrant (who has an obligation to submit data)
to share in the burden of developing that data.  You must also submit to the Agency a completed
EPA Form 8570-32,  Certification of Offer to  Cost Share in the Development of Data, Attachment
7. In addition,  you must demonstrate that the other registrant to whom  the offer was made has
not accepted your offer to enter into a cost sharing agreement by including a copy of your offer
and proof of the other registrant's receipt of that offer (such as  a certified mail receipt). Your
offer must, in addition to anything  else, offer  to share in the burden of producing the data upon
terms to be agreed or  failing agreement to be  bound by binding arbitration as provided by FIFRA
section 3(c)(2)(B)(iii) and must not qualify this offer.   The other registrant must also inform EPA
of its  election of an option to  develop and submit the data required by this Notice by submitting a
Data Call-In Response Form and a  Requirements Status and Registrant's Response Form
committing to develop and  submit the data required by this Notice.

       In order for you to avoid suspension under this option, you may not withdraw your  offer
to share in the burdens of developing the data. In addition, the other registrant must fulfill its
commitment to  develop and submit the data as required by this Notice.  If the  other registrant fails
to develop the data or for some other reason is subject to suspension, your registration as well as
that of the other registrant will normally be subject to initiation of suspension proceedings,  unless
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you commit to submit, and do submit the required data in the specified time frame.  In such cases,
the Agency generally will not grant a time extension for submitting the data.

       Option 4, Submitting an Existing Study — If you choose to submit an existing study in
response to this Notice, you must determine that the study satisfies the requirements imposed by
this Notice.  You may only submit a study that has not been previously submitted to the Agency
or previously cited by anyone.  Existing studies are studies which predate issuance of this Notice.
Do not use this option if you are submitting data to upgrade a study. (See Option 5).

       You should be aware that if the Agency determines that the study is not acceptable, the
Agency will require you to comply with this Notice, normally without an extension of the
required date of submission.  The Agency may determine at any time that a study is not valid and
needs to be repeated.

       To meet the requirements of the DCI Notice for submitting an existing study, all of the
following three criteria must be clearly met:

       a.     You must certify at the time that the existing study is submitted that the raw data
              and  specimens from the study are available for audit and review and you must
              identify where they are available.  This must be done in accordance with the
              requirements of the Good Laboratory Practice (GLP) regulation, 40 CFR Part 160.
              As stated in 40 CFR 160.3(j) "  'raw data'  means any laboratory worksheets,
              records, memoranda, notes, or  exact copies thereof, that are the result of original
              observations and activities of a  study and are necessary for the reconstruction and
              evaluation of the report of that  study.  In the event that exact transcripts of raw
              data have been prepared (e.g.,  tapes which have been transcribed verbatim, dated,
              and  verified accurate by signature), the exact copy or exact transcript may be
              substituted for the original source as raw data.  'Raw data' may include
              photographs, microfilm or microfiche copies, computer printouts, magnetic media,
              including dictated observations, and recorded data from automated instruments."
              The term "specimens",  according to 40 CFR 160.3(k), means "any material
              derived from a test system for examination or analysis."

       b.     Health and  safety studies completed after May 1984 must also contain all GLP-
              required quality assurance and  quality  control information, pursuant to the
              requirements of 40 CFR Part 160.  Registrants must also certify at the time of
              submitting the  existing study that such GLP information is available for post-May
              1984 studies by including an appropriate statement on or attached to the study
              signed by an authorized official or representative of the registrant.

       c.     You must certify that each study fulfills the acceptance criteria for the Guideline
              relevant to the study provided in the FIFRA Accelerated Reregistration Phase 3
              Technical Guidance and that the study has been conducted according to the
              Pesticide Assessment Guidelines (PAG) or meets the purpose of the PAG (both
              available from NTIS).  A study not conducted according to the PAG may be
              submitted to the Agency for consideration if the registrant believes that the study
              clearly meets the purpose of the PAG.  The registrant is referred to 40  CFR 158.70

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              which states the Agency's policy regarding acceptable protocols. If you wish to
              submit the study, you must, in addition to certifying that the purposes of the PAG
              are met by the study, clearly articulate the rationale why you believe the study
              meets the purpose of the PAG, including copies of any supporting information or
              data.  It has been the Agency's experience that studies completed prior to January
              1970 rarely satisfied the purpose of the PAG and that necessary raw data are
              usually not available for such studies.
       If you submit an existing study, you must certify that the study meets all requirements of
the criteria outlined above.

       If you know of a study pertaining to any requirement in this Notice which does not meet
the criteria outlined above but does contain factual information regarding unreasonable adverse
effects, you must notify the Agency of such a study.  If such study is in the Agency's files, you
need only cite it along with the notification. If not in the Agency's files, you must submit a
summary and copies as required by PR Notice 86-5.

       Option 5, Upgrading a Study — If a study has  been classified as partially acceptable and
upgradeable, you may submit data to upgrade that study. The Agency will review the data
submitted and determine if the requirement is satisfied.  If the Agency decides the requirement is
not satisfied, you may still be required to submit new data normally without any time extension.
Deficient, but upgradeable studies will normally be classified as supplemental. However, it is
important to note that not all studies classified as supplemental are upgradeable.  If you have
questions regarding the classification of a study or whether a study may be upgraded, call or write
the contact person listed in Attachment 1.  If you submit data to upgrade an existing study you
must satisfy or supply information to correct all deficiencies in the study identified by EPA.  You
must provide a clearly articulated rationale of how the deficiencies have been remedied or
corrected and why the study should be rated as acceptable to EPA.  Your submission must also
specify the MRID number(s) of the study which you are attempting to upgrade and must be in
conformance with PR Notice 86-5.

       Do not submit additional data for the purpose  of upgrading a study classified as
unacceptable and determined by the Agency as not capable of being upgraded.

       This option should also be used to cite data that  has been previously submitted to upgrade
a study, but has not yet been reviewed by the Agency.  You must provide  the MRID number  of
the data submission as well as the MRID number of the study  being upgraded.

       The criteria for submitting an existing study, as  specified in Option 4 above, apply to  all
data submissions intended to upgrade studies. Additionally your submission of data intended  to
upgrade studies must be accompanied by a certification  that you comply with each of those
criteria as well as a certification regarding  protocol compliance with Agency requirements.

       Option 6, Citing Existing Studies — If you choose to cite a study that has been previously
submitted to EPA,  that study must have been previously classified by EPA as acceptable or it
must be a study which has not yet been reviewed by the Agency.  Acceptable toxicology studies

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generally will have been classified as "core-guideline" or "core minimum." For all other
disciplines the classification would be "acceptable."  With respect to any studies for which you
wish to select this option you must provide the MRID number of the study you are citing and, if
the study has been reviewed by the Agency, you must provide the Agency's classification of the
study.

       If you are  citing a study of which you are not the original data submitter, you must submit
a completed copy  of EPA Form 8570-31, Certification with Respect to Data Compensation
Requirements.

       Registrants who select one of the above 6 options must meet all of the requirements
described in the instructions for completing the Data Call-in Response Form and the Requirements
Status and Registrant's Response  Form, as appropriate.

III-D  REQUESTS FOR DATA WAIVERS

             If you request a waiver for product specific data because you believe it is
inappropriate, you must attach a complete justification for the request, including technical
reasons, data and  references to relevant EPA regulations, guidelines or policies. (Note: any
supplemental data must be submitted in the format required by PR Notice 86-5). This will be the
only opportunity to state the reasons or provide information in support of your  request.  If the
Agency approves your waiver request, you will not be required to supply the data pursuant to
section 3(c)(2)(B)  of FIFRA. If the Agency denies your waiver request, you must choose an
option for meeting the data requirements of this Notice within 30 days of the receipt of the
Agency's decision. You must indicate and submit the option chosen on the Requirements Status
and Registrant's Response Form.  Product specific data requirements for product chemistry, acute
toxicity and efficacy (where appropriate) are required for all products  and the Agency would grant
a waiver only under extraordinary circumstances.  You should also be aware that submitting a
waiver request will not automatically extend the due date for  the study in question.  Waiver
requests submitted without adequate supporting rationale will be denied and the original due date
will remain in force.

IV. CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

IV-A NOTICE OF INTENT TO SUSPEND

       The Agency may issue a Notice of Intent to Suspend products subject to this Notice due  to
failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant to
FIFRA section 3(c)(2)(B).  Events which may be the basis for issuance of a Notice of Intent to
Suspend include, but are not limited to, the following:

       1.     Failure to respond as required by this Notice within 90  days of your receipt of this
             Notice.

       2.     Failure to submit on the required schedule an acceptable proposed or final protocol
             when such is required to be submitted to the Agency for review.
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       3.     Failure to submit on the required schedule an adequate progress report on a study
             as required by this Notice.

       4.     Failure to submit on the required schedule acceptable data as required by this
             Notice.

       5.     Failure to take a required action or submit adequate information pertaining to any
             option chosen to address the data requirements (e.g., any required action or
             information pertaining to submission or citation of existing studies or offers,
             arrangements, or arbitration on the sharing of costs or the formation of Task
             Forces, failure to comply with the terms of an agreement or arbitration concerning
             joint data development or failure to comply with any terms of a data waiver).

       6.     Failure to submit supportable certifications as to the conditions  of submitted
             studies, as required by Section III-C of this Notice.

       7.     Withdrawal of an offer to share in the cost of developing required data.

       8.     Failure of the registrant to whom you have tendered an offer to share in the cost of
             developing data and provided proof of the registrant's receipt of such offer or
             failure of a registrant on whom you rely for a generic data exemption either to:

             a.     inform EPA of intent to develop and submit the data required by this Notice
                    on a Data Call-in Response Form  and a Requirements Status and
                    Registrant's Response Form;

             b.     fulfill the commitment to develop  and submit the data as required by this
                    Notice; or

             c.     otherwise take appropriate steps to meet the requirements stated in this
                    Notice, unless you commit to submit  and do submit the required data in  the
                    specified time frame.

       9.     Failure to take any required or appropriate steps, not mentioned above, at any time
             following the issuance of this Notice.

IV-B.  BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS
UNACCEPTABLE

       The Agency may determine that a study (even if submitted within the required time) is
unacceptable and constitutes a basis for issuance of a Notice of Intent to Suspend.  The grounds
for suspension include, but are not limited to,  failure to  meet any of the following:

       1.  EPA requirements specified in the Data Call-In Notice or other documents incorporated
       by reference  (including, as applicable,  EPA Pesticide Assessment Guidelines, Data
       Reporting Guidelines, and GeneTox Health Effects Test Guidelines) regarding the design,
       conduct, and reporting of required studies.  Such requirements include, but are not limited

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       to, those relating to test material, test procedures, selection of species, number of animals,
       sex and distribution of animals, dose and effect levels to be tested or attained, duration of
       test, and, as applicable, Good Laboratory Practices.

       2.  EPA requirements regarding the submission of protocols, including the incorporation
       of any changes required by the Agency following review.

       3.  EPA requirements regarding the reporting of  data, including the manner of reporting,
       the completeness of results, and the adequacy of  any required supporting (or raw) data,
       including, but not limited to, requirements referenced or included in this Notice  or
       contained in PR 86-5. All studies must be submitted in the form of a final report; a
       preliminary report will not be considered to fulfill the submission requirement.

IV-C EXISTING STOCKS OF SUSPENDED OR CANCELLED PRODUCTS

       EPA has statutory  authority to permit continued sale, distribution and use of existing
stocks of a pesticide product which has been suspended or cancelled if doing so would be
consistent with the purposes of the Act.

       The Agency has determined that such disposition by registrants of existing stocks for a
suspended registration when a section 3(c)(2)(B) data request is outstanding would generally not
be consistent with  the Act's purposes.  Accordingly, the Agency anticipates granting registrants
permission to sell, distribute, or use existing stocks of suspended product(s) only in exceptional
circumstances. If you believe such disposition of  existing stocks of your product(s) which may be
suspended for failure to comply with this Notice should  be permitted, you have the burden of
clearly demonstrating to EPA that granting such permission would be consistent with the Act. You
must also  explain why an  "existing stocks" provision is necessary, including  a statement of the
quantity of existing stocks and your estimate of the time  required for their sale, distribution, and
use.  Unless you meet this burden the Agency will not consider any  request pertaining to the
continued sale, distribution,  or use of your existing stocks after suspension.

       If you request a voluntary cancellation of your product(s) as a response to this Notice and
your product is in  full compliance with all Agency requirements, you will have, under most
circumstances, one year from the date your 90 day response to this Notice is due,  to sell,
distribute, or use existing  stocks.  Normally, the Agency will allow persons other  than the
registrant  such as independent distributors, retailers and  end users to sell, distribute or use such
existing stocks until the stocks are exhausted. Any sale, distribution or use of stocks of
voluntarily cancelled products containing an active ingredient for which the Agency has particular
risk concerns will be determined on case-by-case basis.
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       Requests for voluntary cancellation received after the 90 day response period required by
this Notice will not result in the Agency granting any additional time to sell, distribute, or use
existing stocks beyond a year from the date the 90  day response was due unless you demonstrate
to the Agency that you are in full compliance with  all Agency requirements, including the
requirements of this Notice. For example, if you decide to voluntarily cancel your registration six
months before a 3 year study is scheduled to be submitted, all progress reports and other
information necessary to establish that you have been conducting  the study in an acceptable and
good faith manner must have been submitted to the Agency, before EPA will consider granting an
existing stocks provision.

SECTION V. REGISTRANTS'  OBLIGATION TO REPORT POSSIBLE
UNREASONABLE ADVERSE EFFECTS

       Registrants are reminded  that FIFRA section 6 (a) (2) states that if at any time after a
pesticide is registered a registrant has additional factual information regarding unreasonable
adverse effects on the environment by the pesticide, the registrant shall submit the information to
the Agency.  Registrants must notify the Agency of any factual information they have, from
whatever source, including but not limited to interim or preliminary results of studies, regarding
unreasonable adverse effects on man or the environment. This requirement continues as long as
the products are registered by the Agency.

SECTION VI.  INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding the requirements and procedures established by this
Notice,  call the contact person(s) listed in Attachment 1, the Data Call-In Chemical Status Sheet.
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       All responses to this Notice (other than voluntary cancellation requests and generic data
exemption claims) must include a completed Data Call-in Response Form and a completed
Requirements Status and Registrant's Response Form (Attachment 2 and Attachment 3 for product
specific data) and any other documents required by this Notice, and should be submitted to the
contact person(s) identified in Attachment 1.  If the voluntary cancellation or generic data
exemption option is chosen, only the Data Call-in Response Form need be submitted.

       The Office of Compliance Monitoring (OCM) of the Office of Pesticides and Toxic
Substances  (OPTS), EPA, will be monitoring the data being generated in response to this Notice.

                                        Sincerely yours,
                                        Lois Rossi, Division Director
                                        Special Review and
                                         Reregistration Division
Attachments

       1  -   Data Call-in Chemical Status Sheet
       2  -   Product-Specific Data Call-in Response Form
       3  -   Requirements Status and Registrant's Response Form
       4  -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5  -   List of Registrants Receiving This Notice
       6  -   Cost Share and Data Compensation Forms and the Confidential Statement of
             Formula Form
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HYDROXYPROPYL METHANETHIOSULFONATE DATA CALL-IN CHEMICAL STATUS
SHEET

INTRODUCTION

       You have been sent this Product Specific Data Call-In Notice because you have product(s)
containing Hydroxypropyl methanethiosulfonate.

       This Product Specific Data Call-In Chemical Status Sheet,  contains an overview of data
required by this notice, and point of contact for inquiries  pertaining to the  reregistration  of
Hydroxypropyl methanethiosulfonate.  This attachment is to be used in conjunction with  (1) the
Product Specific Data  Call-In  Notice, (2) the Product  Specific  Data Call-In Response  Form
(Attachment 2), (3) the Requirements Status and Registrant's Form (Attachment 3), (4)  EPA's
Grouping of End-Use Products for Meeting Acute Toxicology Data Requirement (Attachment 4),
(5)  the  EPA Acceptance  Criteria (Attachment 5), (6) a  list of registrants receiving this DCI
(Attachment 6) and  (7) the Cost  Share  and Data Compensation Forms  in  replying to this
Hydroxypropyl methanethiosulfonate Product Specific Data Call-In (Attachment 7).  Instructions and
guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

       The additional  data  requirements  needed to complete the  database for Hydroxypropyl
methanethiosulfonate  are  contained in the  Requirements Status  and Registrant's Response,
Attachment  3.    The  Agency  has concluded that   additional  data  on  Hydroxypropyl
methanethiosulfonate are needed for specific products. These data are required to be submitted to the
Agency within the time frame listed. These data are needed to fully complete the reregistration  of
all eligible Hydroxypropyl methanethiosulfonate products.

INQUIRIES AND RESPONSES TO THIS NOTICE
      If you have any questions regarding this product specific data requirements and procedures
established by this Notice, please contact Moana Appleyard at (703) 308-8175.

      All responses to this Notice for the Product Specific data requirements should be submitted
      to:
             Moana Appleyard
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch 7508W
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE: Hydroxypropyl methanethiosulfonate


                                          55

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   INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM FOR
                             PRODUCT SPECIFIC DATA

Item 1-4.     Already completed by EPA.

Item 5.       If you wish to voluntarily cancel your product, answer "yes."  If you choose this
             option, you will not have to provide the data required by the Data Call-In Notice and
             you will not have to complete any other forms.  Further sale and distribution of your
             product after the effective date of cancellation must be in accordance with the Existing
             Stocks provision of the Data Call-In Notice (Section IV-C).

Item 6.       Not applicable since this form calls in product specific data only.  However, if your
             product is identical to another product and you qualify for a data exemption, you
             must respond with "yes" to Item 7a (MUP) or 7B  (EUP)  on this form, provide the
             EPA registration  numbers  of your source(s);  you would  not complete the
             "Requirements Status and Registrant's Response" form. Examples of such products
             include repackaged products and Special Local Needs (Section 24c) products which
             are identical to federally registered products.

Item 7a.      For each  manufacturing use product (MUP) for which you wish to maintain
             registration, you must agree to satisfy the data requirements by responding "yes."

Item 7b.      For each end use product (EUP) for which you wish to maintain registration, you
             must agree  to satisfy the data requirements by  responding "yes."  If you are
             requesting a data waiver, answer "yes" here; in addition, on  the "Requirements
             Status and  Registrant's Response" form under Item 9, you must respond with Option
             7 (Waiver  Request) for each study for which you are requesting a waiver. See Item
             6 with regard to identical products and data exemptions.

Items 8-11.  Self-explanatory.

NOTE:       You may provide additional information that does not fit on this form in a signed
             letter that accompanies this form.  For example, you may wish to report that your
             product has already been  transferred to another company or that you have already
             voluntarily canceled this product. For these cases,  please  supply all relevant details
             so that EPA can ensure that its records are correct.
                                           56

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               57

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 INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
         REGISTRANT'S RESPONSE FORM FOR PRODUCT SPECIFIC DATA

Item 1-3      Completed by EPA. Note the unique identifier number assigned by EPA in Item
             3.  This number  must be  used in the transmittal document for  any data
             submissions in response to this Data Call-In Notice.

Item 4.       The  guideline reference numbers of studies  required to support the  product's
             continued registration are identified.  These guidelines, in addition to the requirements
             specified in the Notice, govern the conduct of the required studies. Note that series
             61 and 62 in product chemistry are now listed  under 40 CFR 158.155 through
             158.180,  SubpartC.

Item 5.       The study title associated with the guideline reference number is identified.

Item 6.       The use pattern(s) of the pesticide associated with the product specific requirements
             is (are) identified. For most product specific data requirements, all use patterns are
             covered by the data requirements.  In the case of efficacy data, the required studies
             only pertain to products which have the use sites and/or pests indicated.

Item 7.       The substance to be tested is identified by EPA.  For product  specific data, the
             product as formulated  for sale and distribution is the test substance, except in rare
             cases.

Item 8.       The due date for submission of each study is identified. It is normally based on 8
             months after issuance of the Reregistration Eligibility Document unless EPA
             determines that a longer time period is necessary.

Item 9.       Enter only one of the following response codes for each data requirement to show
             how you intend to comply with the data requirements listed in this table.  Fuller
             descriptions of each option are contained in the Data Call-In Notice.

       1.     I  will generate and submit data by the specified due date  (Developing Data). By
             indicating that I have  chosen  this  option, I certify that I will comply with  all the
             requirements pertaining to the conditions for submittal of this study as outlined in the
             Data Call-In Notice. By the specified due date, I will also submit:  (1) a completed
             "Certification With Respect To Data Compensation  Requirements" form (EPA
             Form  8570-29)  and (2) two  completed and  signed  copies of  the  Confidential
             Statement of Formula (EPA Form 8570-4).

       2.     I have entered into an agreement with one or more registrants to develop data jointly
             (Cost Sharing).  I  am submitting a copy of this agreement.  I understand that this
             option is  available only for acute toxicity or certain efficacy data and only if EPA
             indicates in an attachment to this Notice that my product is similar enough to another
             product to qualify for this option.  I  certify that another party in the agreement  is


                                          58

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       committing to  submit or  provide the required data; if the required study is  not
       submitted on time, my product may be subject to  suspension. By the specified  due
       date, I will also submit:  (1)  a  completed "Certification  With Respect To Data
       Compensation Requirements"  form (EPA Form 8570-29) and (2) two completed
       and signed copies of the Confidential Statement of Formula (EPA Form 8570-4).

3.      I have made offers to share in the cost to develop data (Offers to Cost Share).  I
       understand that this option is available only for acute toxicity or certain efficacy data
       and only if EPA indicates in an attachment to this Data  Call-in Notice that my product
       is similar enough to  another product to qualify for  this option.   I am submitting
       evidence that I have made an offer to another registrant (who has an obligation to
       submit data) to share in the cost of that data.  I am also submitting a completed
       "Certification of Offer to Cost Share in the Development Data" form.  I am
       including a copy of my offer and proof of the other registrant's receipt of that offer.
       I am identifying the party which is committing to submit or provide  the required data;
       if the required study is not submitted  on time,  my product may be subject to
       suspension.  I understand that other terms under Option 3 in the Data Call-in Notice
       (Section III-C.l.) apply as  well.   By the specified due date, I will  also submit: (1) a
       completed "Certification  With Respect To Data Compensation Requirements"
       form  (EPA Form 8570-29) and  (2) two completed  and signed  copies of  the
       Confidential Statement of Formula (EPA Form 8570-4).

4.      By the specified due date, I  will submit an existing study that has not been submitted
       previously to the Agency by anyone (Submitting an Existing Study). I certify that
       this study will meet all the requirements for submittal of  existing data outlined in
       Option 4 in the Data Call-In Notice (Section  III-C.l.) and  will  meet the attached
       acceptance criteria (for acute toxicity and product chemistry data). I will attach the
       needed supporting information along with this response.  I also certify that I have
       determined that this study will fill the data requirement for which I have indicated this
       choice.  By the specified due date, I will also submit a completed "Certification With
       Respect To Data Compensation Requirements" form (EPA Form 8570-29) to
       show what data compensation option I have chosen.  By the specified due date, I will
       also submit: (1) a completed "Certification  With Respect  To Data Compensation
       Requirements" form (EPA Form 8570-29) and (2) two completed and signed copies
       of the Confidential Statement of Formula (EPA Form 8570-4).

5.      By the specified due date,  I will submit or cite data to upgrade a study classified by
       the Agency as partially acceptable and upgradable (Upgrading  a Study). I will
       submit evidence of the Agency's review indicating that the study may be upgraded
       and what information is required to do so.  I will provide  the MRID or Accession
       number of the study at the  due date.  I understand that the conditions for this option
       outlined Option 5  in the  Data  Call-In Notice (Section III-C.l.) apply.  By  the
       specified due date, I will also submit: (1)  a completed "Certification With Respect
       To Data Compensation Requirements"  form (EPA Form 8570-29) and (2) two
                                    59

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             completed and signed copies of the Confidential Statement of Formula (EPA Form
             8570-4).

       6.     By the specified due date, I will cite an existing study that the Agency has classified
             as acceptable or an existing study that has been submitted but not reviewed by the
             Agency  (Citing an Existing Study).  If I am citing another registrant's study, I
             understand that this option is available  only for acute toxicity or certain efficacy data
             and only if the cited study was conducted on my product, an identical product or a
             product which EPA has "grouped" with one or more other products for purposes of
             depending on the same data. I may  also choose this option if I am citing my own
             data.  In either case, I will provide the MRID or Accession number(s) for the cited
             data on  a "Product Specific Data Report" form or in a similar format.  By the
             specified due  date,  I will also submit:  (1) a  completed "Certification With Respect
             To Data Compensation Requirements" form (EPA Form 8570-29)  and (2) two
             completed and signed copies of the Confidential Statement of Formula (EPA Form
             8570-4).

       7.     I request a waiver for this study because it is inappropriate for my product (Waiver
             Request). I am attaching a complete justification for this request, including technical
             reasons, data and  references to relevant EPA regulations, guidelines  or  policies.
             [Note: any supplemental data must be submitted in the format required by  P.R. Notice
             86-5]. I understand that this is my only opportunity to state the reasons or provide
             information in support of my request.  If the Agency approves my waiver request, I
             will not be required to supply the data pursuant to Section 3(c) (2) (B)  of FIFRA. If
             the Agency denies  my waiver request, I must choose a method of meeting the data
             requirements of this Notice by the due date stated by this Notice.  In  this case, I must,
             within 30 days of my receipt of the Agency's written decision,  submit a revised
             "Requirements Status and Registrant's  Response" Form indicating the option chosen.
             I also understand that the deadline for submission of data as specified by the original
             data call-in notice will not change.  By the specified due date, I will also submit: (1)
             a completed "Certification With Respect To Data Compensation Requirements"
             form (EPA  Form 8570-29)  and (2)  two completed and signed copies of the
             Confidential Statement of Formula (EPA Form 8570-4).

Items 10-13.  Self-explanatory.

NOTE:      You may provide additional information  that does not fit on this form in a signed
             letter that accompanies this form.  For example, you may wish to report that your
             product has already been transferred to another company or that  you have already
             voluntarily canceled this product. For these cases, please supply all relevant details
             so that EPA can ensure that its records are  correct.
                                           60

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               61

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               62

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               63

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               64

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EPA'S BATCHING OF HYDROXPROPYLMETHANE THIOSULFONATE (HPMTS)
PRODUCTS FOR MEETING ACUTE TOXICITY DATA REQUIREMENTS FOR
REREGISTRATION

       In an effort to reduce the time, resources and number of animals needed to fulfill the
acute toxicity data requirements for reregistration of products containing HPMTS as the active
ingredient,  the Agency has batched products which can be considered similar for purposes of
acute toxicity. Factors considered in the sorting process include each product's active and inert
ingredients (identity, percent composition and biological activity), type of formulation (e.g.,
emulsifiable concentrate, aerosol, wettable powder, granular, etc.), and labeling (e.g., signal
word, use classification, precautionary labeling, etc.).  Note that the Agency is not describing
batched products as "substantially similar" since some  products within a batch may not be
considered  chemically similar or have identical use patterns.

       Using available information,  batching has been accomplished by the process described in
the preceding paragraph. Notwith-standing the batching process, the Agency reserves the right to
require, at  any time, acute toxicity data for an individual product should the need arise.

       Registrants of products within a batch may choose to cooperatively generate, submit or
cite a single battery of six acute toxicological studies to represent all the products within that
batch. It is  the registrants' option to participate in the process with all other registrants, only
some of the other registrants,  or only their own products within a batch, or to generate  all the
required acute toxicological studies for each of their own products.  If a registrant chooses to
generate the data for a batch, he/she must use one  of the products within the batch as the test
material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she
may do so provided that the data base is complete and  valid by today's standards (see acceptance
criteria  attached), the formulation tested is considered  by EPA to be similar  for acute toxicity,
and the  formulation has not been significantly altered since submission and acceptance of the
acute toxicity data. Regardless of whether new data is  generated or existing data is referenced,
registrants  must clearly identify the test material by EPA Registration Number.  If more than one
confidential statement of formula (CSF) exists for  a product,  the registrant must indicate the
formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow
the directions given in the Data Call-In Notice and its attachments appended to the RED. The
DCI Notice contains two response forms which are to  be completed and submitted to the Agency
within 90 days of receipt.  The first form,  "Data Call-In Response," asks whether the registrant
will meet the data requirements for each product.  The second form, "Requirements Status and
Registrant's Response," lists the product specific data required for each product, including the
standard six acute toxicity tests.  A registrant who wishes to participate in a  batch must decide
whether he/she will provide the data or depend on someone else to do so.  If a registrant supplies
the data to  support a batch of products, he/she must select one of the following options:
Developing Data (Option 1), Submitting an Existing Study (Option 4), Upgrading an Existing
Study (Option 5) or Citing an Existing Study (Option  6). If a registrant depends on another's


                                            65

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data, he/she must choose among: Cost Sharing (Option 2), Offers to Cost Share (Option 3) or
Citing an Existing Study (Option 6). If a registrant does not want to participate in a batch, the
choices  are Options 1, 4, 5 or 6. However, a registrant should know that choosing not to
participate in a batch does not preclude other registrants in the batch from citing his/her studies
and offering to cost share (Option 3) those studies.

       Nine products were found which contain HPMTS as the active ingredient. The  products
have been placed into three batches and a "no batch" category in accordance with the active and
inert ingredients, type of formulation and current labeling. Table 1 identifies the batched
products. Table 2 lists 1 product that was considered not to be similar to any other product and
has been placed in the "no batch" category.

 Table  1
Batch
1

2



3

EPA Reg. No.
1448-31
1448-36
1448-76
1448-77
1448-78
1448-79
1448-27
1448-30
% Active Ingredient
80.0
80.0
25.0
15.0
10.0
5.0
32.0
14.6
Formulation Type
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
 Table 2  (No Batch)
EPA Reg. No.
1448-90
% Active Ingredient
10.0
Formulation Type
Liquid
       The products in Batch 1 are considered technicals and have been reviewed in the RED
Toxicology Chapter.  Data are sufficient to label these products and no additional data needs to
be submitted.  In addition,  as the active ingredient is considered to be a dermal sensitizer, all
products containing this active ingredient should be labeled for dermal sensitization. No
additional dermal sensitization studies need be submitted.  Inhalation toxicity has been waived for
all products also, because the use pattern precludes inhalation exposure.

       There is sufficient information on acute toxicity to label the products in Batch 2 with the
following exceptions:
                                             66

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       A primary dermal irritation study is needed for 1448-76 and 1448-77.  A category III
       result from 1448-76 could be bridged to 1448-77.

       A primary eye irritation study is needed for 1448-79.

For Batch 3, an acute oral and dermal toxicity  study is needed for 1448-27.  Primary dermal and
eye irritation studies are needed for both 1449-27 and 1448-30.

       There is sufficient information on acute toxicity to label 1448-90 with the exception  of the
acute oral toxicity study.  The study on file is inconclusive with regard to the LD50 in female
animals.  The study must be repeated.
                                            67

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               68

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    ATTENTION CRM::: PLEASE NOTE:::
REMOVE THIS PAGE AND INSERT THE LIST OF
    REGISTRANTS RECEIVING THIS DCI
                       69

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Instructions for Completing the Confidential Statement of Formula

The Confidential Statement of Formula (CSF) Form 8570-4 must be used. Two legible, signed
copies of the form are required.  Following are basic instructions:

      a. All the blocks on the form must be filled in and answered completely.

      b.     If any block is not applicable, mark it N/A.

      c.     The CSF must be signed, dated and the telephone number of the responsible party
             must be provided.

      d.     All applicable information which is on the product specific data submission must
             also be reported on the CSF.

      e.     All weights reported under item 7 must be in pounds per gallon for liquids and
             pounds per cubic feet for solids.

      f.     Flashpoint must be in degrees Fahrenheit and flame extension in inches.

      g.     For all active ingredients, the EPA Registration Numbers for the currently
             registered source products must be reported under column 12.

      h.     The Chemical Abstracts Service (CAS)  Numbers for all actives and inerts and all
             common names for the trade names must be reported.

      i.     For the active ingredients, the percent purity of the source products must be
             reported under column 10 and must be exactly the same as on the source product's
             label.
      j.     All the weights in columns 13.a. and 13.b. must be in pounds, kilograms, or
             grams. In no case will volumes be accepted. Do not mix English and metric
             system units (i.e., pounds and kilograms).

      k.     All the items under column  13.b. must total 100 percent.

      1.     All items under columns 14.a. and 14.b. for the active ingredients must represent
             pure active form.

      m.    The upper and lower certified limits for ail active and inert ingredients must follow
             the 40 CFR 158.175 instructions. An explanation must be provided if the proposed
             limits are different than standard certified limits.

      n.     When new CSFs are submitted and approved, all previously submitted CSFs
             become obsolete for that specific formulation.
                                           70

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              72

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    r/EPA
United  States  Environmental  Protection Agency
            Washington,  DC  20460
   CERTIFICATION  OF OFFER TO COST
SHARE  IN THE  DEVELOPMENT  OF DATA
Form Approved

OMB No.  2070-0106
         2070-0057

Approval  Expires  3-31-96
 Public reporting burden for this collection of information is estimated to average 15 minutes per response, including
 time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
 completing and reviewing the collection of information.  Send comments regarding the burden estimate or any other
 aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy
 Branch, PM-223, U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20460; and to the Office
 of Management and Budget,  Paperwork Reduction Project (2070-0106), Washington, DC 20503.

 Please fill in blanks below.
  Company Name
                                                                            Company Number
  Product Name
                                                                            EPA Reg. No.
 I Certify that:

 My company is willing to develop and submit the data required by EPA under the authority of the Federal
 Insecticide, Fungicide and Rodenticide Act (FIFRA), if necessary.  However, my company would prefer to
 enter into an agreement with one or more registrants to develop jointly or share in the cost of developing
 data.

 My firm has offered in writing to enter into such an agreement. That offer was irrevocable and included an
 offer  to be bound by arbitration decision under section 3(c)(2)(B)(iii) of FIFRA if final agreement on all
 terms could not be reached otherwise.  This offer was made to the following firm(s) on the following
 date(s):
  Name of Firm(s)
                                                                             Date of Offer
Certification:
I certify that I am duly authorized to represent the company named above, and that the statements that I have made on
this form and all attachments therein are true, accurate, and complete. I acknowledge that any knowingly false or
misleading statement may be punishable by fine or imprisonment or both under applicable law.
 Signature of Company's Authorized Representative
                                                                            Date
 Name and Title (Please Type or Print)
 EPA Form 8570-32 (5/91)    Replaces EPA Form 8580, which is obsolete
                                                  73

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              74

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                         United States Environmental Protection Agency
                                     Washington, DC 20460
  CERTIFICATION WITH RESPECT TO
DATA COMPENSATION REQUIREMENTS
                                                                               '
                                                                      Form Approved
                                                                      OMB No. 2070-0107,
                                                                      2070-0057
                                                                      Approval Expires
                                                                      3-31-96
  Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for
  reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the
  collection of information.  Send comments regarding the burden estimate or any other aspect of this collection of information,
  including suggestions for reducing this burden to, Chief Information Policy Branch, PM-233, U.S.  Environmental Protection
  Agency, 401 M St., S.W., Washington, DC 20460; and to the Office of Management and Budget,  Paperwork Reduction Project
  (2070-0106), Washington, DC 20503.

  Please fill in blanks below.
Company Name
Product Name
Company Number
EPA Reg. No.
  I Certify that:

  1.    For each study cited in support of registration or reregistratiion under the Federal Insecticide, Fungicide and Rodenticide Act
  (FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the written permission of the original
  data submitter to cite that study.

  2.    That for each study cited in support of registration or reregistration under  FIFRA that is NOT an exclusive use study, I am  the
  original data submitter, or I have obtained the written permission of the original data submitter, or I have notified in writing the
  company(ies) that submitted data I  have cited and have offered to: (a) Pay compensation for those data in accordance with sections
  3(c)(1 )(F) and 3(c)(2)(D) of FIFRA;  and (b) Commence negotiation to determine which data are subject to the compensation
  requirement of FIFRA and the amount of compensation due, if any. The companies I have notified are. (check one)

   [  ] The companies who have submitted the studies listed on the back of this form or attached sheets, or indicated on the attached
  "Requirements Status and Registrants' Response Form,"

  3.    That I  have previously complied with  section 3(c)(1)(F) of FIFRA for the studies I have cited in support of registration or
  reregistration under FIFRA.
Signature
Date
  Name and Title (Please Type or Print)
  GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, with regard to the registration or
  reregistration of my products, to the extent required by FIFRA section 3(c)(1)(F) and 3(c)(2)(D).
Signature
Date
  Name and Title (Please Type or Print)
EPA Form 8570-31 (4-96)
                                                           75

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              76

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    The following is a list of available documents for Hydroxypropyl methanethiosulfonate that
my further assist you in responding to this Reregistration Eligibility Decision document. These
documents may be obtained by the following methods:

Electronic
File format:  Portable Document Format  (.PDF) Requires Adobe® Acrobat  or  compatible
             reader.  Electronic copies can  be downloaded from the Pesticide Special Review
             and Reregistration Information System at 703-308-7224.  They also are available
             on the Internet on EPA's gopher server, GOPHER.EPA.GOV, or using ftp on
             FTP.EPA.GOV, or using WWW (World Wide Web) on WWW.EPA.GOV., or
             contact Moana Appleyard at (703)-308-8175.

    1.        PR Notice 86-5.

    2.        PR Notice 91-2 (pertains to the Label Ingredient Statement).

    3.        A full copy of this RED  document.

    4.        A copy  of the fact sheet  for Hydroxypropyl methanethiosulfonate.


    The  following  documents are  part of the  Administrative Record  for  Hydroxypropyl
methanethiosulfonate and may included in the EPA's Office of Pesticide Programs Public Docket.
Copies of these documents are not available electronically, but may be obtained by contacting the
person listed on the Chemical Status Sheet.

    1.        Health and Environmental Effects Science Chapters.

    2.        Detailed Label Usage Information System (LUIS)  Report.

    The following Agency reference documents are not available electronically, but may be
obtained by contacting the person listed on the  Chemical Status Sheet of this RED document.

    1.        The Label Review Manual.

    2.        EPA Acceptance Criteria
                                          77

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
CERTIFIED MAIL
Dear Registrant:

       I am pleased to announce that the Environmental Protection Agency has completed its
reregistration eligibility review and decisions on the pesticide chemical case and active
ingredient hydroxypropyl methanethiosulfonate. The enclosed Reregistration Eligibility
Decision (RED) contains the Agency's evaluation of the data base of these chemicals, its
conclusions of the potential human health and environmental risks of the current product uses,
and its decisions and conditions under which these uses and products will be eligible  for
reregistration. The RED includes the data and labeling requirements for products for
reregistration. It may also include requirements for additional data (generic) on the active
ingredients to confirm the risk assessments.

       To assist you with a proper response, read the enclosed document entitled  "Summary
of Instructions for Responding to the RED." This summary also refers to other enclosed
documents which include further instructions. You  must follow all instructions and submit
complete and timely responses. The first set of required responses is due 90 days  from the
receipt of this letter.  The second  set of required responses is due 8 months from the date
of this letter.  Complete and timely responses will avoid the Agency taking the enforcement
action of suspension against your products.

       If you have questions on the product  specific data requirements or wish to  meet with
the Agency, please contact the Special  Review and Reregistration Division representative
Moana Appleyard (703)  308-8175.  Address any questions on required generic data to the
Special Review and Reregistration Division  representative Patrick Dobak (703) 308-8180.

                                                     Sincerely yours,
                                                     Lois Rossi, Division Director
                                                     Special Review
                                                     and Reregistration Division
Enclosures

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              SUMMARY OF INSTRUCTIONS FOR RESPONDING TO
             THE REREGISTRATION ELIGIBILITY DECISION (RED)

1.  DATA CALL-IN (PCI) OR "90-DAY RESPONSE"  If generic data are required for
reregistration, a DCI letter will be enclosed describing such data.  If product specific data
are required, a DCI letter will be enclosed listing such requirements.  If both generic and
product specific data are required, a combined Generic and Product Specific DCI letter will
be enclosed describing such data.  However, if you are an end-use product registrant only  and
have been granted a generic data exemption (GDE) by EPA, you are being sent only the
product specific response forms (2 forms) with the RED.  Registrants responsible for generic
data are being sent response forms for both generic and product specific data requirements (4
forms).  You must submit  the appropriate response forms (following the instructions
provided) within 90 days of the receipt of this RED/DCI letter; otherwise, your product
may be suspended.

2.  TIME EXTENSIONS AND DATA WAIVER REQUESTS No time extension requests
will be granted for the 90-day response.  Time extension requests may be submitted only with
respect to actual data submissions.  Requests for time  extensions for product specific data
should be submitted in the 90-day response.  Requests for  data waivers must be submitted  as
part of the 90-day response.  All data waiver and time extension requests must be accompanied
by a full justification. All waivers and time extensions must be granted by EPA in order to go
into effect.

3.  APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE"  You must
submit the following items for each product within eight months of the date of this letter
(RED issuance date).

      a. Application for Reregistration (EPA Form 8570-1). Use only an original
application form.  Mark it "Application for Reregistration."  Send your Application for
Reregistration (along with the other forms listed in b-e below) to the address listed in item 5.

      b. Five copies of draft labeling which complies with the RED and current regulations
and requirements.  Only make labeling changes which are  required by the  RED and current
regulations (40 CFR 156.10) and policies.  Submit any other amendments  (such as formulation
changes, or labeling changes not related to reregistration) separately.  You may, but are not
required to, delete uses which the RED says are ineligible  for reregistration.  For further
labeling guidance, refer to the labeling section of the EPA publication "General Information
on Applying for Registration in the U.S., Second Edition,  August 1992" (available from the
National Technical Information Service, publication #PB92-221811;  telephone number 703-
487-4650).

      c. Generic or Product Specific Data. Submit all data in a format which complies
with PR Notice 86-5, and/or submit citations of data already submitted and give the EPA
identifier (MRID) numbers.  Before citing these studies, you must make sure that they meet
the Agency's acceptance criteria (attached to the DCI).

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      d. Two copies of the Confidential Statement of Formula (CSF) for each basic and
each alternate formulation.  The labeling and CSF which you submit for each product must
comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal
concentration.  You have two options for submitting a CSF: (1) accept the standard certified
limits  (see 40 CFR §158.175) or (2) provide certified limits that are supported by the analysis
of five batches.  If you choose the second option, you must submit or cite the data for the five
batches along with a certification statement as described in 40 CFR §158.175(e).  A copy of
the CSF is enclosed; follow the instructions on its back.

      e. Certification With Respect to Data Compensation Requirements.  Complete and
sign EPA form  8570-31 for each product.

4. COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE Comments
pertaining to the content of the RED may be submitted to the address shown in the Federal
Register Notice which announces the availability of this RED.

5. WHERE TO SEND PRODUCT SPECIFIC PCI RESPONSES (90-DAY) AND
APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      EPA, 401 M St. S.W.
      Washington, D.C. 20460-0001

By express:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      Room 266A, Crystal Mall 2
      1921 Jefferson Davis Hwy.
      Arlington, VA 22202

6. EPA'S REVIEWS—EPA will screen all submissions for completeness; those which are not
complete will be returned with a request for corrections. EPA will try to respond to data
waiver and time extension requests within  60 days. EPA will also try to respond to all 8-
month submissions with a final reregistration determination within 14 months after the RED
has been issued.

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   REREGISTRATION ELIGIBILITY DECISION

HYDROXYPROPYLMETHANETHIOSULFONATE

                      LISTC

                    CASE 3033
               ENVIRONMENTAL PROTECTION AGENCY
                 OFFICE OF PESTICIDE PROGRAMS
            SPECIAL REVIEW AND REREGISTRATION DIVISION

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                         TABLE OF CONTENTS
HYDROXYPROPYL METHANETHIOSULFONATE REREGISTRATION ELIGIBILITY
      DECISION TEAM	i

EXECUTIVE SUMMARY	v

I.     INTRODUCTION	1

II.    CASE OVERVIEW	2
      A.    Chemical Overview 	2
      B.    Use Profile 	2
      C.    Estimated Usage of Pesticide  	4
      D.    Regulatory History and Data Requirements  	4

III.   SCIENCE ASSESSMENT	4
      A.    Physical Chemistry Assessment	4
      B.    Human Health Assessment	5
           1.    Toxicology Assessment	5
                 a.    Acute Toxicity  	5
                 b.    Subchronic Toxicity	6
                 c.    Chronic Toxicity/Carcinogenicity	7
                 d.    Developmental Toxicity  	7
                 e.    Reproductive Toxicity  	7
                 f.     Mutagenicity  	8
                 g.    Metabolism  	8
                 h.    Toxic Endpoints of Concern  	8
           2.    Exposure and Risk Assessment	9
                 a.    Dietary Exposure and Risk Assessment	9
                 b.    Occupational and Residential Exposure and Risk Assessment
                         	9
      C.    Environmental Assessment	10
           1.    Ecological Toxicity Data  	10
                 a.    Toxicity to Terrestrial Animals  	10
                 b.    Toxicity to Aquatic Animals  	11
                 c.    Toxicity to Plants  	13
           2.    Environmental Fate   	13
                 a.    Environmental Fate Assessment	13
                 b.    Environmental Fate and Transport  	13
           3.    Exposure and Risk Characterization  	14

IV.   RISK MANAGEMENT AND REREGISTRATION DECISION	14
      A.    Determination of Eligibility	14

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      B.    Determination of Eligibility Decision	15
            1.     Eligibility Decision  	15
            2.     Eligible and Ineligible Uses   	15
            3.     Endangered Species Protection	15
      C.    Regulatory Position  	15
            1.     Risk Mitigation Measures/ Labeling Rationale	16
            2.     Entry Restrictions	17
            3.     Addition and Retention of Other Label Statements	17

V.    ACTIONS REQUIRED OF REGISTRANTS 	17
      A.    Manufacturing-Use Products	17
            1.     Additional Generic Data Requirements	17
            2.     Labeling Requirements for Manufacturing-Use Products	18
      B.    End-Use Products  	18
            1.     Additional Product-Specific Data Requirements	18
            2.     Labeling Requirements for End-Use Products	19
      C.    Existing Stocks 	21

VI.   APPENDICES  	23
      APPENDIX A.    Table of Use Patterns Subject to Reregistration  	24
      APPENDIX B.    Table of the Generic Data Requirements and Studies Used to
            Make the Reregistration Decision	33
      APPENDIX C.    Citations Considered to be Part of the Data Base Supporting the
            Reregistration of Hydroxypropyl methanethiosulfonate   	39
      APPENDIX D.    Product Specific Data Call-in  	45
            Attachment 1.     Chemical Status Sheets	59
            Attachment 2.     Product Specific Data Call-in Response Forms (Form A
                  inserts)  Plus Instructions  	60
            Attachment 3.     Product Specific Requirement Status and Registrant's
                  Response Forms (Form B inserts) and Instructions	62
            Attachment 4.     EPA  Batching of End-Use Products for Meeting Data
                  Requirements for Reregistration	69
            Attachment 5.     List of All Registrants Sent This Data Call-in (insert)
                  Notice	73
            Attachment 6.     Cost  Share, Data Compensation Forms,  Confidential
                  Statement of Formula Form and Instructions 	74
      APPENDIX E.    List of Available Related Documents	82

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HYDROXYPROPYL METHANETHIOSULFONATE REREGISTRATION
ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:

Biological and Economic Analysis Assessment
Ghulam Ali
Steve Jarboe
Cynthia Szymanski

Environmental Fate and Effects Assessment

Ann Stavola
Mary Frankenberry
Rachelle Kudrik
Jose Melendez

Health  Effects Assessment

Arliene Aikens
Tom Campbell
Paula Deschamp
Steven  Malish

Registration Support

Valdis  Goncarovs
Tina Levine
Shyam  Mathur

Risk Management

Kathleen Depukat
Patrick Dobak

Office  of Compliance:

Carol Buckingham
Economic Analysis Branch
Biological Analysis Branch
Biological Analysis Branch
Ecological Effects Branch
Science Analysis and Coordination Staff
Science Analysis and Coordination Staff
Environmental Fate and Groundwater Branch
Risk Characterization and Analysis Branch
Occupational and Residential Exposure Branch
Risk Characterization and Analysis Branch
Toxicology Branch II
Antimicrobial Program Branch
Reregistration Support Branch
Reregistration Support Branch
Accelerated Reregistration Branch
Accelerated Reregistration Branch
Agriculture and Ecosystem Division

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               11

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            GLOSSARY OF TERMS AND ABBREVIATIONS

ADI            Acceptable Daily Intake.  A now defunct term for reference dose (RfD).
AE            Acid Equivalent
a.i.            Active Ingredient
ARC           Anticipated Residue Contribution
CAS           Chemical Abstracts Service
CI             Cation
CNS           Central Nervous  System
CSF           Confidential Statement of Formula
DFR           Dislodgeable Foliar Residue
ORES          Dietary Risk Evaluation System
DWEL         Drinking Water Equivalent Level (DWEL) The DWEL represents a medium specific (i.e.
               drinking water) lifetime exposure at which adverse, non carcinogenic health effects are not
               anticipated to occur.
EEC           Estimated Environmental Concentration. The estimated pesticide concentration in an
               environment, such as a terrestrial ecosystem.
EP            End-Use  Product
EPA           U.S. Environmental Protection Agency
FDA           Food and Drug Administration
FIFRA         Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA        Federal Food, Drug, and Cosmetic Act
FOB           Functional Observation Battery
GLC           Gas Liquid Chromatography
GM           Geometric Mean
GRAS          Generally Recognized as Safe as Designated by FDA
HA            Health Advisory  (HA).  The HA values are used as informal guidance to municipalities and
               other organizations when emergency spills or contamination situations occur.
HOT           Highest Dose Tested
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.
LDlo           Lethal Dose-low. Lowest Dose at which lethality occurs.
LEL           Lowest Effect  Level
LOG           Level of Concern
LOD           Limit of Detection
LOEL          Lowest Observed Effect Level
MATC         Maximum Acceptable Toxicant Concentration
MCLG         Maximum Contaminant Level Goal (MCLG)  The MCLG is used by the Agency to regulate
               contaminants in drinking water under the Safe Drinking Water Act.
Hg/g           Micrograms Per Gram
mg/L           Milligrams Per Liter
MOE           Margin of Exposure
MP            Manufacturing-Use Product
MPI           Maximum Permissible Intake
MRID          Master Record Identification (number).  EPA's system of recording and tracking studies
               submitted.
N/A           Not Applicable
NOEC          No effect concentration
                                                 111

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            GLOSSARY  OF TERMS AND ABBREVIATIONS

NPDES        National Pollutant Discharge Elimination System
NOEL          No Observed Effect Level
NOAEL        No Observed Adverse Effect Level
OP            Organophosphate
OPP           Office of Pesticide Programs
PADI          Provisional Acceptable Daily Intake
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
PRN           Pesticide Registration Notice
Q*!            The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model
RBC           Red Blood Cell
RED           Reregistration Eligibility Decision
REI            Restricted Entry Interval
RfD           Reference Dose
RS            Registration Standard
SLN           Special Local Need (Registrations Under Section 24 (c) of FIFRA)
TC            Toxic Concentration. The concentration at which a substance produces a toxic effect.
TD            Toxic Dose. The dose at which a substance produces a toxic effect.
TEP           Typical End-Use Product
TGAI          Technical Grade Active Ingredient
TLC           Thin Layer Chromatography
TMRC         Theoretical Maximum Residue Contribution
torr            A unit of pressure needed to support a column of mercury 1 mm high under standard conditions.
FAO/WHO     Food and Agriculture Organization/World Health Organization
WP            Wettable Powder
WPS           Worker Protection Standard
                                                IV

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EXECUTIVE SUMMARY

       As required under the Federal Insecticide, Fungicide, and Rodenticide Act, as amended
in 1988, the U.S. Environmental Protection Agency has completed its reregistration eligibility
decision for the pesticide active ingredient hydroxypropyl methanethiosulfonate (HPMTS).
This decision includes a comprehensive reassessment of the required target data base and use
patterns of currently registered products.  The Agency compared its risk assessment to current
science and regulatory policies. The Agency has determined that the uses as described below
will not cause unreasonable risk to humans or the environment and all uses are eligible for
reregistration. Where appropriate, the Agency has imposed additional use restrictions and
precautionary statements for product labels to reduce risks to human health and the
environment.

       Use Patterns

       HPMTS is a microbiocide/microbiostat used to control slime-forming algae, bacteria,
and fungi in commercial/industrial water cooling systems, industrial processing water,
pulp/paper mill water systems, and is used as a preservative in industrial coatings, emulsions,
paints and wet-end additives/industrial processing chemicals.  It is applied by direct pouring
and metered application.

       Human Health Assessment

       From its review of the toxicology data,  the Agency concluded that HPMTS is mildly to
moderately toxic when administered by oral or dermal routes.  The chemical is corrosive and
is considered to be a severe dermal and eye irritant. The chemical caused delayed contact
hypersensitivity in the guinea pig dermal sensitization studies.  The subchronic dermal LOEL
was determined to be 250 mg/kg/day for systemic toxicity and 10 mg/kg/day for dermal
toxicity.  A battery of mutagenicity studies was negative for mutagenic effects. Two
developmental toxicology studies were reviewed.  The rat maternal LOEL and NOEL were
determined to be 30 mg/kg/day and 10 mg/kg/day, respectively. The rabbit maternal LOEL
and NOEL were determined to be 4.0 mg/kg/day and 0.75 mg/kg/day, respectively.

       No dietary exposure to  HPMTS is expected from the current use patterns.  Although
corrosiveness and dermal sensitization were identified as potential effects, significant
occupational exposures are not expected.  Therefore, quantitative assessments of exposures
and risks were deemed unnecessary and not conducted. To mitigate the potential risks of
corrosiveness and dermal sensitization to workers, minimum (baseline) personal protective
equipment  (PPE) is being required for the handling of concentrated products. Non-
occupational exposures are not expected.

       Environmental Assessment

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       HPMTS is moderately toxic to slightly toxic to avian species on an acute and subacute
oral dietary basis, slightly toxic to fish, and moderately toxic to aquatic invertebrates.  Current
uses of HPMTS are expected to result in minimal exposure or risk to the environment.
Therefore, no additional environmental risk mitigation measures are being imposed at this
time.

       Product Reregistration

       The Agency is requiring that product specific data, revised Confidential Statements of
Formula (CSF) and revised labeling be submitted within eight months of the issuance of this
document for all products containing HPMTS.  These data include product chemistry and
acute toxicity testing for each registration.  After reviewing these revised labels and finding
them acceptable in accordance with Section 3(c)(5) of FIFRA, the Agency will reregister each
associated product. Those products that contain other active ingredients will be eligible for
reregistration only when the other active ingredients are determined to be eligible for
reregistration.
                                            VI

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended
to accelerate the reregistration of products with active ingredients registered prior to November
1,  1984. The amended Act provides a schedule for the  reregistration process to be completed in
nine years. There are five phases to the reregistration process. The first four phases of the process
focus on identification of data requirements to support the  reregistration of an active ingredient
and the generation and submission of data to fulfill the requirements.  The fifth phase is a review
by the U.S. Environmental Protection Agency (referred to as "the Agency") of all data submitted
to support reregistration.

       FIFRA Section 4(g)(2)(A)  states that in Phase  5  "the Administrator shall determine
whether pesticides containing such active ingredient are  eligible for reregistration" before calling
in  data  on products and either reregistering products or taking "other appropriate regulatory
action."  Thus, reregistration involves a thorough review  of the scientific data base underlying a
pesticide's registration.  The purpose of the Agency's review is to reassess the potential  hazards
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  the pesticide meets the "no
unreasonable adverse effects"  criterion of FIFRA.

       This document presents the Agency's decision  regarding the reregistration eligibility of
the registered uses of 2-hydroxypropyl methanethiosulfonate (HPMTS). The document  consists
of six sections. Section I is  the  introduction. Section  II describes HPMTS,  its uses,  data
requirements and regulatory history.  Section III discusses  the human health and environmental
assessment  based  on the data available  to  the Agency.  Section IV presents the reregistration
decision for HPMTS. Section  V discusses the reregistration requirements for HPMTS.  Finally,
Section  VI is the Appendices which support this Reregistration Eligibility Decision. Additional
details concerning the Agency's review of applicable data are  available on request.

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II.    CASE OVERVIEW

      A.     Chemical Overview

             The following  active  ingredient is covered by this Reregistration  Eligibility
      Decision:

      •      Common Name:           HPMTS

      •      Chemical Name:           2-hydroxypropyl methanethiosulfonate

      •      Chemical Family:         Thiosulfonates

      •      CAS Registry Number:    30388-01-3

      •      OPP Chemical Code:      35604

      •      Empirical Formula:        C4HnS203

      •      Trade and Other Names:   S-(2-hydroxypropyl) thiomethanesulfonate

      •      Basic Manufacturer:       Buckman Labs

      B.     Use Profile

             The following is information on the currently  registered uses with an overview of
      use sites and application methods.  A detailed table  of these  uses of HPMTS is in
      Appendix A.

      For 2-hydroxypropyl methanethiosulfonate:

      Type of Pesticide:   Microbiocide/microbiostat  (slime-forming algae,  bacteria  and
                         fungi), Bacteriostat.

      Use Sites:          AQUATIC NON-FOOD INDUSTRIAL

                                Commercial/Industrial  Water Cooling Systems
                                Industrial Processing Water
                                Pulp/Paper Mill Water Systems

                         INDOOR NON-FOOD

                                Industrial Coatings
                                Resin/Latex/Polymer Emulsions

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                          Latex/Oil/Varnish Paints (Applied Film)
                          Wet-End Additives/Industrial Processing  Chemicals
Target Pests: Slime-forming algae, bacteria and fungi

                                 End-use, Manufacturing-use
Formulation Types  TYPE:
Registered:
                    FORM:
                    PURITY:
Soluble Concentrate/Liquid, Ready-To-Use Solution
/Liquid

Single Active Ingredient
TGAI: 80%
End-Use Products: 5-80%
Multiple Active Ingredients
End-Use Products: 11.7-28%
Method and Rates   Equipment - Direct pour, metered application (registrant must
of Application:      specify on labeling). For Rates of application see Table 1 below.

                    Timing - During manufacture, Not specified (registrant must supply
                    on labeling).
Table 1 - Method and Rate
TREATMENT
TYPE
Water (recirculating)
Water (recirculating)
Water
Industrial
Preservative
Industrial
Preservative
Industrial
Preservative
Industrial
Preservative
SYSTEM TYPE
Commercial/Industrial Cooling Systems
Industrial Processing
Pulp/Papermill
Industrial Coatings
Resin/Latex/Polymer Emulsions
Latex/Oil/Varnish Paints (applied film)
Wet-End Additives/ Industrial Processing
Chemicals
RATE (ppm AI
by weight)
0.4 to 8. 5
0.4 to 4. 3
0.176 to 281
400 to 4050
400 to 4050
280 to 2800
400 to 4050

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       Use Practice
       Limitations:         NPDES license restriction.

       C.    Estimated Usage of Pesticide

             Information about the use and percentage of sites treated with  HPMTS is not
       readily available.  However, the aggregate annual use of this pesticide is considered to be
       quite small in the United States, based on proprietary sources.

       D.    Regulatory History and Data Requirements

             Products containing HPMTS as an active ingredient were registered in the United
       States as early as  1968.  Currently, nine products  are registered to one registrant for the
       uses described above.

             In March, 1987, the Agency issued the Anti-Microbial Data Call-In Notice for
       toxicity and exposure data requirements for this active ingredient  and other antimicrobials.
       Additionally, the Agency  issued  a September, 1992 Phase IV Data Call-In requiring
       studies on product chemistry, human health, and ecological effects data to support the uses
       listed. Appendix B includes all data requirements  identified by the Agency for currently
       registered uses needed to support reregistration.

III.    SCIENCE ASSESSMENT

       A.    Physical Chemistry Assessment

             Molecular Weight:   171.25

             Color:               Light yellow/brilliant yellow

             Odor:               Strong sour, pungent vegetable-like odor

             Boiling Point:        164°C

             Density:             1.2893  at 22°C
             Solubility:

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Table 2 - HPMTS Solubility
Solvent
Ethanol
Hexane
C8_18 Fatty Acids
Water
Solubility
Miscible in all proportions
< 16 mg in 100 ml
Mean fat solubility at 37 °C
At concentrations > 40%,
concentrations < 40%, not
is5.42 + 0.04g/100g
soluble at any concentration; at
completely soluble
              Vapor Pressure:     1.40 mm Hg at 20°C and 1.70 mm Hg at 25°C.

              pH:                 3.7at22°C.

       B.     Human Health Assessment

              1.     Toxicology Assessment

                    The toxicological data base on HPMTS is adequate to support reregistration
              eligibility.

                    a.     Acute Toxicity
Table 3 - Acute Human Health Studies
Type of Study
Acute Oral - rat
Acute Dermal - rat
Acute Inhalation
Primary Eye Irritation*
Primary Dermal Irritation*
Dermal Sensitization - guinea pig*
Results [mg/kg]
LD5n  2000
Waived
Waived
Waived
Sensitizer
Toxicity Category
II
III
NA
I
I
NA
* This study is a requirement for manufacturing-use and end-use products (40 CFR 158).
applicable
NA = not
                           In an acute oral toxicity study in the rat, HPMTS (81.45% a.i.) was
                    administered by oral gavage to 5 animals/sex and observed for 14 days.
                                            5

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Compound related clinical signs presented were transient hypoactivity and
staggered gait in surviving rats. Reddening of glandular stomach mucosa
and the gastrointestinal tract were seen. (MRID 41634701)

       In an acute dermal toxicity study in the rat, HPMTS (81.45% a.i.)
was  administered by dermal  application at  2  gm/kg  (limit  dose) to 5
animals/sex for 14 days.  Dermal irritation was present in all animals and
included erythema, edema, fissuring, hemorrhaging, blanching,  atonia, and
a leathery feel to the skin.  The dose used in the study was the limit dose
specified in the guidelines. (MRID 41632401)

       An acute inhalation study was waived  because the absence  for
potential for inhalation exposure (no respirable particles) is indicated by the
current HPMTS use pattern.  The  primary dermal irritation and eye
irritation studies were waived because HPMTS was corrosive in the 14 and
90-day dermal studies.

       In a guinea pig dermal sensitization study, HPMTS (40%  a.i.) was
found to be a sensitizer. HPMTS caused delayed contact hypersensitivity.
(MRID 42349201)

b.     Subchronic  Toxicity

       In  a two-week, repeat dose (range finding), dermal toxicity study
conducted in the rat, HPMTS (79.67% a.i.) as a  30% solution  [in distilled
water] was applied to 5 animals/sex at doses of 0, 100, 250, 500, 750 or
1000 mg/kg/day, for 6 hours/day,  5 days/week for 14  days.   Control
animals received distilled water.  A dose related irritation was presented
with eschar, and exfoliation at 500 to 750 mg/kg/day.  The dermal no
observable effect level (NOEL) was < 100  mg/kg/day (lowest dose tested).
(MRID 40747102)

       In  a dermal toxicity study in rats,  HPMTS  (79.67% a.i.), at a
concentration  of 5.0%, was applied to approximately  10% of  the body
surface area of 10 animals/sex at doses of 0, 10, 50 or 250 mg/kg/day.
Exposure was for 6 hours/day, 5 days/week for 91 days.  Control animals
received distilled water under the same experimental conditions.

       Slight  treatment-related  reductions  in  body weight and food
consumption  were  found in the  high dose males.  Compound-related
reductions in erythrocyte counts, hematocrit and hemoglobin occurred in
both high dose males and females as compared to the respective  controls.
A slight but significant increase in the platelet count occurred in the high
dose in both sexes.

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       Compound  and dose-related dermal irritation was  found in  the
treated animals at the application site.  The severity of the irritation ranged
from minimal in the low-dose animals to severe in the high-dose animals
of  both  sexes.  Surface  exudate,  dermal  inflammation,  and  fibrosis
occasionally  accompanied  the ulceration  in  the high-dose  animals.
Microscopic examination confirmed the gross observation of the skin in the
high dose animals as ulceration and acanthotic epidermal thickening.

       Based on changes in body weights and hematology at the high dose,
the lowest observable effect level  (LOEL)  for systemic toxicity is 250
mg/kg/day and the NOEL is 50 mg/kg/day. The LOEL for dermal toxicity
is  10 mg/kg/day, the lowest dose tested. (MRID 40974701)

c.      Chronic Toxicity/Carcinogenicity

       Chronic toxicity and carcinogenicity studies are not required for
HPMTS because the non-food use pattern scenarios currently registered are
not likely to result in significant human exposure.

d.     Developmental Toxicity

       A developmental toxicity study conducted in the rat,  evaluated
HPMTS  (79.67% a.i.) at doses of 0, 10, 30 or 75 mg/kg/day by gavage
from gestation days 6 to 15. The maternal NOEL was 10 mg/kg/day and
the maternal LOEL was 30 mg/kg/day based on salivation, rales, and oral-
nasal  discharge.  The developmental NOEL was  10 mg/kg/day  and  the
developmental LOEL was  30 mg/kg/day based on reduced fetal weight.
(MRID 41010501)

       Another developmental toxicity study conducted by gavage in the
rabbit, evaluated HPMTS  (79.67%) at doses of 0, 0.75, 4.0 or  7.5
mg/kg/day from gestation days 6 to 18.  The maternal NOEL and LOEL
were 0.75 mg/kg/day and 4.0 mg/kg/day, respectively, based on decreased
body  weights.  The developmental  NOEL was >7.5 mg/kg/day (HDT).
(MRID 41010401)

e.      Reproductive Toxicity

       A  reproductive toxicity study  is not required  to  support  the
currently registered non-food uses of HPMTS because  the use pattern
scenarios are not likely to result in significant human exposure.

f.      Mutagenicity

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             In a gene mutation (Reverse Mutation)  study, HPMTS  (79.67%
       a.i.)  did not produce gene  mutation in an Ames  assay  in which S.
       typhimurium (TA98, TA100, TA1535 and TA1538) bacteria were tested
       without activation up to 0.25 jjl/plate and with activation up to 0.5  jjl/plate.
       Concentrations >0.5 jjl/plate produced cytotoxicity.  (MRID 40229601)

              HPMTS (80% a.i.) was negative both with and without activation
       in a Sister Chromatid Exchange (SCE) In Vitro/'CHO assay when assayed
       at concentrations into the toxic range (16.7 jig/ml).  (MRID 40420201)

             In the DNA Damage/Repair in Primary Rat Hepatocytes  study,
       HPMTS (80% a.i.) was negative for inducing UDS at concentration levels
       into the toxic range (100 jig/ml and higher). (MRID 40420202)

       g.     Metabolism

             A metabolism study is not required  to support non-food uses of
       HPMTS because of the expected absence of oral  exposure and because the
       current use pattern scenarios are not likely to result in significant human
       exposure.

       h.     Toxic Endpoints of Concern

             Based on HPMTS' target database  for toxicology, the Agency
       concludes there are no toxicological endpoints  of concern  for HPMTS.
       While technical HPMTS has been demonstrated to be corrosive and lead to
       dermal  sensitization from acute  exposures, these concerns are  more
       appropriately addressed during product reregistration after a re-assessment
       of each product's acute toxicity.

       Reference Dose (RED)

             A reference dose was not established for HPMTS, based on the non-
       food  use patterns and exposure profile (The Agency's Office of Pesticide
       Programs RfD Committee report, February 15,  1995)

       WHO/JMPR Status

             The World Health Organization/Joint Meeting on Pesticide Residues
       committee has not reviewed this pesticide.

2.     Exposure and Risk Assessment

       a.     Dietary Exposure and Risk Assessment
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                    There are no registered food uses of HPMTS, therefore, a dietary
              exposure and risk assessment are not required.

              b.     Occupational and Residential Exposure and Risk Assessment

                    An occupational/residential exposure assessment is required for an
              active ingredient if:  (1)  certain toxicological criteria are triggered and (2)
              there is potential exposure to handlers (M/L/A) during use or to persons
              entering treated sites  after  application  is complete.  Since  toxicology
              endpoints  of concern, except for corrosiveness and dermal sensitization
              from acute exposures, were not identified for  occupational/residential
              exposures,  an  occupational/residential  M/L/A  exposure analysis and
              quantitative risk assessment are not warranted at this time.

                    The Agency has  determined that products containing  HPMTS
              labeled and used as  specified in this RED will not pose significant risk to
              humans. The most significant occupational concerns are for corrosiveness
              and dermal sensitization from acute  exposures.   The  use  of minimal
              (baseline)  PPE  , including chemical  resistant  gloves  and  apron and
              faceshield, will adequately mitigate these hazards.

                    A short term  (1 to 7 days) occupational/residential risk  assessment
              is not required, since results from the 14-day dermal toxicity study do not
              indicate any toxicological  endpoints appropriate for use in the standard
              occupational or residential exposure assessments.  Also, an intermediate (1
              week to several months) occupational/residential risk assessment is not
              required based on a comparison of the 90-day repeated-dose dermal toxicity
              and the  oral developmental  toxicity studies  conducted in rats.  In these
              studies, the LOEL(s) were 250 mg/kg/day and 30 mg/kg/day, respectively.
              On  the  basis  that the  dermal LOEL was  significantly higher, it was
              determined that dermal absorption of HPMTS is limited.  Also, inhalation
              exposures are not expected because respirable particles are not anticipated
              to be produced from  the application methods (open-pour or metered pump)
              and because of the chemical's low vapor pressure.

                    Most of HPMTS' use and exposure are associated with industrial
              applications.  Additionally, people who apply HPMTS treated paint or who
              reside or work in buildings which have painted with such paint may also be
              exposed to HPMTS. However,  because of the Agency's conclusion on
              HPMTS' risks from subchronic exposures and because  of HPMTS' low
              vapor pressure, the Agency believes risks to these individuals are very low.
C.     Environmental Assessment

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1.      Ecological Toxicity Data

       a.      Toxicity to Terrestrial Animals

              (1)    Birds, Acute and Subacute

                    In order to establish the toxicity of HPMTS to birds, the
              following tests are required for industrial microbiocides using the
              technical grade material:  one avian single-dose oral (LD50) study
              on one species (preferably the bobwhite quail or mallard duck);  one
              subacute  dietary  study  (LC50) on one  species  (preferably  the
              bobwhite quail).   The available information is summarized in the
              following tables:
Table 4 - Avian Acute Oral Toxicity Findings
Species
Mallard Duck
% A.I.
79.82
LD50 mg/kg
>474.4 mg/kg
Toxicity Category
moderately toxic
                    Although  the  avian  acute  oral  study  yielded  some
              information, it was not considered acceptable  because  the birds
              regurgitated shortly after dosing.  The registrant is performing a
              new study in order to fulfill guideline requirements.
Table 5 - Avian Subacute Dietary Toxicity Findings
Species
Northern Bobwhite Quail
Mallard Duck
% A.I.
79.82
79.82
LC50 ppm
>3991
>3991
Toxicity Category
slightly toxic
slightly toxic
                    The results from the subacute study and the supplemental
              results of the acute oral study indicate that HPMTS is slightly to
              moderately toxic  to avian species on  an acute oral and subacute
              dietary basis. (MRID 249523 for all three)

              (2)    Birds, Chronic

                    Avian reproduction studies are required when birds may be
              exposed  repeatedly   or  continuously  through  persistence,
              bioaccumulation,   or  multiple applications, or   if mammalian
              reproduction tests indicate reproductive hazard. Since the currently
                              10

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       registered uses are for indoor use only, repeated exposures are not
       expected and chronic avian studies are not required.
       (3)
       Mammals
b.
       Wild mammal testing is required on a case-by-case basis,
depending on the results of the lower tier studies such as acute and
subacute testing, intended use pattern, and pertinent environmental
fate characteristics.  In most cases, however, an acute oral LD50 is
used to indicate toxicity to  mammals.   The LD50, as reported in
Table 3 above,  indicates that HPMTS is slightly toxic to small
mammals on an acute oral basis. No additional testing on mammals
is required for these use patterns. (MRID  41634701)

Toxicity to Aquatic Animals

(1)     Freshwater Fish
              (a)
              Acute
                    In order to establish the toxicity  of a pesticide to
              freshwater fish, the minimum data required for industrial
              microbiocides is one freshwater fish toxicity study on the
              technical grade of the active ingredient.  The study should
              preferably use the rainbow trout (cold water species) or the
              bluegill  sunfish  (warm  water species).   The available
              information is summarized in the following table.
Table 6 - Freshwater Fish Acute Toxicity Findings
Species
Rainbow trout
Bluegill sunfish
% A.I.
81.45
81.45
LC50 (ppm)
28.0
38.2
Toxicity Category
slightly toxic
slightly toxic
                    The results  of  the  96-hour acute  toxicity studies
              indicate that HPMTS is slightly toxic to both cold and warm
              water fish.  The guideline  requirements  are  fulfilled.
              (MRIDs 41733203 and 41733201,  respectively)

              (b)    Chronic
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              The fish early life-stage and fish life-cycle tests are
       not required because the products are not applied directly to
       water  or  expected to be transported to water  from the
       intended use site.  Additionally, the fish early life-stage test
       is not required because the LC50 in this case is greater than
       1 mg/L.

(2)     Freshwater Invertebrates

       (a)     Freshwater Invertebrates,  Acute

              The  minimum testing required to  establish the
       toxicity of a microbiocide to freshwater invertebrates is a
       freshwater aquatic invertebrate  toxicity test, preferably
       using first instar Daphnia magna or early instar amphipods,
       stoneflies, mayflies, or midges.  The results of the toxicity
       findings are presented in the table below.
Table 7 - Freshwater Invertebrate Toxicity Findings
Species
Daphnia magna
% A.I.
79.82
EC50 (ppm)
3.13
Toxicity Category
moderately toxic
(3)
       There  is sufficient  information to  characterize
HPMTS as moderately toxic to aquatic invertebrates. The
guideline requirement is fulfilled.  (MRID 41733202)

(b)    Freshwater Invertebrates, Chronic

       The same conditions for chronic testing to freshwater
fish also apply to aquatic invertebrates as discussed in (l.b.)
above. Chronic aquatic invertebrate studies are not required
for HPMTS.

Estuarine and Marine Animals
       (a)
       Acute
              Although  estuarine/marine  testing was originally
       required,  a  waiver  for those  data  requirements was
       subsequently  granted  in  response  to  the  registrants'
       incorporation of a statement on all HPMTS labels restricting
                12

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                    the discharge of HPMTS directly or indirectly into estuarine
                    or marine environments to NPDES permitted discharges.

                    (b)    Chronic

                           The same conditions for chronic testing to freshwater
                    fish and aquatic invertebrates also apply to estuarine  and
                    marine animals as discussed in (l.b.) above.  Therefore, the
                    chronic  estuarine/marine studies for HPMTS  are  not
                    required.

       c.     Toxicity to Plants

             Terrestrial and aquatic plant testing are currently not required, in
       most cases, for industrial microbiocides, including HPMTS.

2.     Environmental Fate

       a.     Environmental Fate Assessment

             Due to the current use patterns for HPMTS, the Agency requires
       only a hydrolysis study for the reregistration target data base.

       b.     Environmental Fate and Transport

             (1)    Degradation

             Hydrolysis

                    [2-14C]2-hydroxypropyl methanethiosulfonate, at 101 mg/L,
             hydrolyzed with half-lives of > 30 days at pH 5, 8.5-9.9 hours at
             pH 7, and 5.4-6.1 minutes at pH 9 in sterile  aqueous buffered
             solutions  at 25°C in the  dark for  up to 30 days.  Two major
             degradates were observed.

                    One  degradate, di-(2-hydroxyisopropyl)disulfide, was  a
             maximum of 24-29% of the recovered at 20 or 30  days in the pH
             5  solution; 61-64% of the recovered at  24.5 hours  in the pH  7
             solution;  and 63-66%  at 15.0-15.2 minutes in the  pH 9 solution.
             The other major degradate, di-(2-hydroxypropyl) disulfide, was a
             maximum of 5.9% of the recovered at  22-30 days  in the pH  5
             solution;  10-12% at 24.5 hours in the pH 7 solution; and 8.17% at
             10.1-15.2 minutes in the pH 9 solution. This study was found to be
                             13

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                           acceptable and satisfies all data requirements for HPMTS. (MRID
                           41475207)

              3.     Exposure and Risk Characterization

                    The Agency requires only a limited set of ecotoxicology and environmental
              fate studies for microbicides. HPMTS is slightly to moderately toxic to birds and
              aquatic invertebrates. While the hazard to aquatic organisms from HPMTS has
              been characterized, a quantitative risk assessment has not been conducted.   The
              risks to aquatic environments from its industrial aquatic uses are regulated under
              the NPDES permitting program of EPA's Office of Water.  The Agency currently
              requires that labels for all  HPMTS products  require that discharges to aquatic
              environments comply with an NPDES permit.

IV.    RISK MANAGEMENT AND REREGISTRATION DECISION

       A.     Determination of Eligibility

              Section 4(g)(2)(A) of  FIFRA calls for the Agency to determine,  after submission
       of relevant data concerning an active ingredient, whether products containing the active
       ingredient are eligible  for reregistration.   The Agency has previously identified and
       required the submission of the generic  (i.e. active  ingredient specific) data required to
       support reregistration of products containing the active ingredient HPMTS.  The Agency
       has completed its review  of these generic data,  and  has determined that the data are
       sufficient  to support reregistration of all  products containing HPMTS.   Appendix B
       identifies  the generic  data  requirements  that the Agency  reviewed as  part of its
       determination of reregistration eligibility of HPMTS, and lists the submitted studies that
       the Agency found acceptable.

              The data identified in Appendix B were sufficient to allow the Agency to assess the
       registered uses of HPMTS and to determine that HPMTS can be used without resulting
       in unreasonable adverse effects  to humans  and the environment.  The Agency therefore
       finds that all products containing HPMTS as the active ingredient, and as specified in this
       document, are eligible for reregistration.   The reregistration of particular products is
       addressed  in Section V  of this document.

              The Agency made its reregistration eligibility determination based upon the target
       data  base  required for  reregistration, the current guidelines for  conducting acceptable
       studies to generate such data, published scientific  literature, and the data identified in
       Appendix  B.  Although the  Agency has found that all uses of HPMTS are eligible for
       reregistration, it should be understood that the Agency may take appropriate regulatory
       action, and/or require  the submission of additional data to support the registration of
       products containing HPMTS,  if new information comes to the Agency's attention or if the
       data requirements for registration (or the guidelines for generating such data) change.


                                           14

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B.     Determination of Eligibility Decision

       1.      Eligibility Decision

              Based on the reviews of the generic data for the active ingredient HPMTS,
       the Agency has sufficient information on the health effects of HPMTS and on its
       potential for causing adverse effects in fish and wildlife and the environment. The
       Agency has determined that HPMTS products, labeled and used as specified in this
       Reregistration  Eligibility Decision,  will not pose unreasonable risks or adverse
       effects to humans or the environment.   Therefore, the Agency concludes that
       products  containing HPMTS for all  uses are eligible for reregistration.

       2.      Eligible and Ineligible Uses

              The Agency has determined that all uses of HPMTS, as specified in this
       document, are eligible for reregistration.

       3.      Endangered Species Protection

              Currently,  the Agency is developing a program ("The Endangered Species
       Protection Program") to identify all pesticides whose use may cause  adverse
       impacts  on  endangered  and threatened  species and  to  implement mitigation
       measures that will  eliminate the adverse impacts.  The program would require use
       restrictions to  protect endangered and threatened species at the county  level.
       Consultations with the Fish and Wildlife Service may be necessary to assess risks
       to newly listed species or from proposed new uses. In the future, the Agency plans
       to publish a description of the Endangered Species Program in the Federal Register
       and have available voluntary county-specific bulletins.  Because the Agency is
       taking this approach for protecting  endangered and threatened species, it is not
       imposing label modifications at this time through  the  RED.   Rather, any
       requirements for  product use modifications will occur in the future under the
       Endangered Species Protection Program.

C.     Regulatory Position

       The following is a summary of the regulatory positions and rationales for HPMTS.
Where labeling revisions are imposed, specific language is set forth in Section V of this
document.

       1.      Risk Mitigation Measures/  Labeling Rationale

       Minimum (baseline) PPE requirements
                                    15

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       If EPA has no special concerns about the acute effects of other adverse
effects of an active ingredient, the PPE for pesticide handlers will be based on the
acute toxicity of the end-use product.  For occupational-use products, PPE must
be established  using the process described in PR Notice 93-7 or more  recent
guidelines.

       If EPA has special concerns about an active ingredient due to very high
acute toxicity or to certain other adverse effects, such as allergic effects or delayed
effects (cancer, developmental toxicity, reproductive effects, etc.):

       •      In the RED for that active ingredient, EPA may establish minimum
              or "baseline" handler PPE requirements that pertain to all or most
              end-use products containing that active ingredient.
       •      These minimum PPE requirements must be compared with the PPE
              that would be designated on the basis of the acute toxicity of the
              end-use product.
       •      The more stringent choice for each type of PPE (i.e., bodywear,
              hand protection, footwear, eyewear, etc.)  must be placed  on the
              label of the end-use product.

Occupational-Use Products

       Primary Occupational Handlers:  EPA has determined that regulatory
action regarding the  establishment  of  active-ingredient-based minimum PPE
requirements for occupational handlers must be taken for HPMTS.  EPA notes that
HPMTS has the potential to cause severe (corrosive) effects to the skin and eyes
and is a dermal sensitizer. No traditional risk assessment needs to be performed
to assess risks due to corrosiveness and sensitization. However, EPA believes that
primary occupational handlers who are exposed to concentrated end-use products
should wear PPE in addition to the baseline long-sleeve shirt, long pants,  shoes,
and  socks.  Therefore,  EPA is  requiring the use of chemical-resistant gloves,
chemical-resistant apron, and face shield for such handlers.

       Secondary Occupational Handlers: At this time, EPA believes that risks
from skin/eye  corrosiveness  and dermal sensitization would be acceptable for
secondary occupational handlers, since the  HPMTS in such products as paints and
adhesives is very diluted, usually far  less  than one percent.

Homeowner-Use Products

       Primary Homeowner Handlers:  All HPMTS end-use pesticide products
are intended primarily for occupational use.
                             16

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                    Secondary Homeowner Handlers: At this time, EPA believes that risks
             from inhalation exposures and skin/eye corrosiveness would be acceptable for
             adhesives, metal-cutting fluids, wood products, and textiles is very diluted, usually
             far less than one percent.

             2.     Entry Restrictions

                    EPA is not establishing entry restrictions for end-use products containing
             HPMTS because the use pattern scenarios are not likely to result in significant
             human exposure to HPMTS.

             3.     Addition and Retention of Other Label Statements

                    The Agency believes it is prudent to require additional use precautions to
             afford product users increased protection from unnecessary exposure to HPMTS.
             For  similar reasons the Agency is retaining current worker and environmental
             restrictions and precautions for risk reduction. Also, all products must have their
             labels improved with adequate and specific directions for use including application
             methods, equipment, timing, and  rates. These label requirements are specified
             below in Section V.

V.     ACTIONS  REQUIRED OF REGISTRANTS

       This section specifies the data requirements and responses necessary for the reregistration
of both manufacturing-use and end-use products.

       A.    Manufacturing-Use Products

             1.     Additional Generic Data Requirements

                    The generic data base supporting the reregistration of HPMTS for the
             above eligible uses has been reviewed and determined to be substantially complete.
             No additional generic  data  are required  at this time.   The registrant is in the
             process of performing an avian acute oral study to confirm the potential hazards
             to avian species.  The study is due for  submission to the Agency by August 19,
             1996.

             2.     Labeling Requirements for Manufacturing-Use Products

                    To remain  in compliance with FIFRA, manufacturing-use product (MP)
             labeling must be revised to comply with all current EPA regulations, PR Notices
             and applicable policies.  The MP labeling must bear the following statement under
             Directions for Use:
                                          17

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              "Only for formulation into a microbiocide/microbiostat, bacteriostat for the
              following  uses:  Commercial/Industrial  Recirculating  Water  Cooling
              Systems, Industrial  Processing Water,  Pulp/Paper Mill  Water Systems,
              Industrial Coatings,  Resin/Latex/Polymer Emulsions, Latex/Oil/Varnish
              Paints,  and Wet-End Additives/Industrial Processing Chemicals."

              An MP registrant may, at his/her discretion, add one of the following
       statements to an MP label under "Directions for Use" to permit the reformulation
       of the product for a specific use or all additional uses supported by a formulator
       or user group:

              (a)     "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)."

              (b)     "This product may be used to formulate products for any additional
              use(s) not listed on the MP label if the formulator or user group has
              complied with U.S. EPA submission requirements regarding support of
              such use(s)."

                           Effluent Discharge Labeling Statements

              "Do not use in facilities discharging directly or indirectly to the estuarine
              or marine environment."

                    To reduce environmental risk from HPMTS discharge and disposal,
              product labels must include the statements pertaining to effluent discharge
              under the NPDES  permitting system  (refer  to  PR  Notice 93-10)  and
              disposal under  any applicable federal laws after the above statement.

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 product specific data requirements are listed in Appendix G, the
       Product Specific Data Call-In Notice.

              Registrants must review previous data submissions to ensure that they meet
       current EPA acceptance criteria (Appendix F; Attachment E) and if not, commit
       to conduct new studies.  If a  registrant believes that previously submitted data meet
       current testing standards, then study MRID numbers should be cited according to


                                    18

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the instructions in the Requirement Status and Registrants Response Form provided
for each product.

2.     Labeling Requirements for End-Use Products

       a.     Occupational  Labeling  PPE  Requirements  for  Pesticide
       Handlers

             Sole-active-ingredient end-use  products that contain HPMTS must
       be revised to remove any conflicting PPE requirements on their current
       labeling.

             Multiple-active-ingredient end-use products that contain HPMTS
       must compare the handler personal protective equipment requirements set
       forth in this section to the PPE requirements on their current labeling and
       retain the more  protective. For guidance on which PPE is considered more
       protective, see  PR Notice 93-7.

             The PPE for each HPMTS occupational end-use product must be
       established based on the acute toxicity of each end-use product. If the end-
       use product is classified as toxicity category I or II for acute eye irritation
       potential (or the eye  irritation  study is waived due  to corrosiveness),
       protective eyewear must be required  for all handlers of HPMTS.  If the
       end-use product is classified as toxicity category I or II for acute skin
       irritation  potential  (or  the skin  irritation  study  is  waived  due  to
       corrosiveness),  chemical-resistant gloves and a chemical-resistant apron
       must be required for all handlers of HPMTS.

             Minimum  (Baseline) PPE/Engineering Control Requirements
             for Products Intended Primarily for Occupational Use

                    The  minimum  (baseline)  PPE for occupational  uses  of
             HPMTS end-use products is:

                    "Mixers, loaders,  and others exposed  to  the concentrate
                    must wear:
                    —Long-sleeve shirt and long pants,
                    —Chemical-resistant gloves*,
                    —shoes plus socks,
                    —chemical-resistant apron, and
                    —face shield."

             * For the glove statement, use the statement established for HPMTS
             through the instructions in Supplement Three of PR Notice 93-7.

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       However, the corrosiveness and penetration of HPMTS itself must
       be considered and appropriate chemical-resistant materials must be
       listed.

Placement in Labeling

       The personal protective equipment language must be placed on the
end-use product labeling in the location specified in PR Notice 93-7 and the
format and language  of  the  PPE requirements must be  the same as  is
specified in PR Notice 93-7.

b.     Other Label Requirements

       The Agency is requiring the following labeling statements to be
located on all end-use products containing HPMTS.

       (1)    Directions for use

             Registrants must specify on labeling the  complete directions
       for use for each use pattern: site of application,  type of application,
       timing of application, equipment used for application, and the rate
       of application (dosage).

       (2)    Application restrictions

       "Do not use this product in a way that will contact workers
       or other persons."

       (3)    Skin sensitizer statement

       "This product may  cause skin  sensitization reactions  in some
       people."

       (4)    User safety recommendations

             For all HPMTS end-use products:

       "Users should wash hands before eating, drinking, chewing gum,
       using tobacco, or using the toilet."

       "Users should remove clothing immediately if pesticide gets inside.
       Then wash thoroughly and put on clean clothing."

       For HPMTS end-use products "gloves" if gloves are required PPE:

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                    "Users should remove Personal Protective Equipment immediately
                    after handling  this product.  Wash the outside of gloves before
                    removing.  As soon as possible, wash thoroughly."

                    (5)    Effluent Discharge Labeling Statements

                           Refer to subsection A. above for labeling requirements for
                    effluent discharge.

C.     Existing Stocks

       Registrants may generally distribute and sell products bearing  old labels/labeling
for 26 months from the date of the issuance of this Reregistration Eligibility Decision
(RED). Persons other than the registrant may generally distribute or sell such products for
50 months from the date  of the issuance of this RED.  However, 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. Refer to "Existing Stocks of Pesticide
Products;  Statement of Policy"; Federal Register, Volume 56, No. 123, June 26, 1991.

       The Agency has determined that registrants may distribute and sell hydroxypropyl
methanethiosulfonate products bearing old labels/labeling for 26 months from the date of
issuance of this RED.  Persons other than the registrant may distribute  or sell such
products for 50 months from the  date of the issuance  of this RED.  Registrants and
persons other than registrants remain obligated to meet pre-existing Agency imposed label
changes and existing stocks requirements applicable to products they sell or distribute.
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VI. APPENDICES

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                                      Case 3033[Busan 74  (*)]
                                APPENDIX A

                                       Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                                          Form(s
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
Min.  Appl.       Max.  Appl.  Soil Max. # Apps Max. Dose  [(AI   Min.  Restr.      Geographic  Limitations       Use
Rate  (AI un-      Rate  (AI Tex. @ Max. Rate unless  noted     Interv Entry    Allowed           Disallowed   Limitations
less noted    unless noted Max. /crop /year otherwise)/A]    (days) Interv                                  Codes
otherwise)       otherwise)  Dose cycle       /crop    /year          [day(s)]
                                            cycle
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED
Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
Water treatment  (recirculating system),
Intermittent  (slug) (initial), Not on
label, Not Applicable, Not applicable for
this use
Water treatment  (recirculating system),
Intermittent  (slug)(subsequent), Not on
label, Not Applicable, Not applicable for
this use
EMULSIONS, RESIN/LATEX/POLYMER

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
                                                   W 2.1

                                                   W 2.1

                                                   W .4
                                                                       W  4000    *   NS     NS          NS       NS    NS

                                                                       W  4050    *   NS     NS          NS       NS    NS

                                                                          Use Group:  AQUATIC  NON-FOOD INDUSTRIAL

                                                                        W 8 . 1    *   NS     NS          NS       NS    NS
                     W 8 . 3   *  NS    NS         NS

                     W 8 . 5   *  NS    NS         NS

                      Use Group: INDOOR NON-FOOD

                    W 4000   *  NS    NS         NS
                                                                                        25

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                                      Report  Run Date:  11/22/95
                                      PRD  Report Date:  04/18/95
                                      Case 3033[Busan 74  (*)]
)   Time 10:53
                                                      LUIS 2.2 - Page:
                                                                                APPENDIX A REPORT
                                                                                          Chemical  035604[S-(2-Hydroxypropyl)  thiomethanes]
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
                                        /year
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED (con't)
PAINTS, LATEX/OIL/VARNISH  (APPLIED FILM)

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
PULP/PAPER MILL WATER SYSTEMS

Water treatment, Not on label, Not on     SC/L
label, Not Applicable, Not applicable for
this use

                                          SC/L

                                          SC/L

                                          SC/L

                                          SC/L

WET-END ADDITIVES/INDUSTRIAL PROCESSING CHEMICALS

Industrial preservative treatment, During SC/L
manufacture, Not on label, Not
Applicable, Not applicable for this use
        W 4 .2    *   NS     NS          NS

        W 4 . 3    *   NS     NS          NS

         Use Group:  INDOOR NON-FOOD

       W 2800    *   NS     NS          NS
          W 4    *   NS     NS          NS

          W 4    *   NS     NS          NS

       W 4.05    *   NS     NS          NS

        W 281    *   NS     NS          NS

         Use Group:  INDOOR NON-FOOD

       W 4000    *   NS     NS          NS
                                                                                        26

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                                      Report Run Date:  11/22/95
                                      PRD Report Date:  04/18/95
                                      Case 3033[Busan 74  (*)]
              )   Time 10:53
                                                                               Page:
                                                                                APPENDIX A REPORT
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only)  & Effica-
  cy Influencing Factor  (Antimicrobial only)
Min. Appl.
Rate  (AI un-
less noted
otherwise)
                         Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                        4444444444444444444444^
  Max.  Appl.  Soil Max.  # Apps Max. Dose  [(AI   Min.  Restr.
    Rate  (AI Tex. @ Max. Rate unless noted     Interv Entry
unless noted Max. /crop /year otherwise)/A]    (days) Interv
  otherwise)  Dose cycle       /crop    /year          [day(s)
                              cycle
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED  (con't)
WET-END ADDITIVES/INDUSTRIAL PROCESSING CHEMICALS  (con't)

                                           SC/L     W  400

                                           SC/L     W  405
                      Use Group: INDOOR NON-FOOD  (con't)

                    W 4000   *  NS    NS          NS       NS    NS      NS

                    W 4050   *  NS    NS          NS       NS    NS      NS
                                                                                        27

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                                      Report  Run Date:  11/22/95  )   Time 10:53                                         LUIS 2.2 - Page:    4
                                      PRD  Report Date:  04/18/95
                                                                                APPENDIX A REPORT

                                      Case 3033[Busan 74  (*)]                             Chemical  035604[S-(2-Hydroxypropyl)  thiomethanes]
LEGEND
444444
  HEADER ABBREVIATIONS
  Min .  Appl .  Rate (AI unless :  Minimum dose for a single application to a single  site.   System  calculated.  Microbial  claims  only.
  noted otherwise)
  Max .  Appl .  Rate (AI unless :  Maximum dose for a single application to a single  site.   System  calculated.
  noted otherwise)
                             :  Maximum dose for a single application to a single  site as  related  to  soil  texture  (Herbicide claims  only) .
                             :  Maximum number of Applications at Maximum Dosage Rate.   Example: "4 applications per  year"  is  expressed as  "4/1  yr";  "4  applications per 3
                               years" is expressed as "4/3 yr"
                             :  Maximum dose applied to a site over a single crop  cycle  or year.   System calculated.
                               Minimum Interval between Applications  (days)
                 terv  (days) :
  PRD Report Date            :



  SOIL TEXTURE FOR MAX APP. RATE
  *       :  Non-specific
  C       :  Coarse
  M       :  Medium
  F       :  Fine
  O       :  Others

  FORMULATION CODES
  SC/L    :  SOLUBLE CONCENTRATE/LIQUID

  ABBREVIATIONS
          :  As Needed
          :  Not Applicable
          :  Not Specified  (on label)
          :  Unconverted due to lack of data  (on label), or with one of following units: bag, bait,  bait  block,  bait  pack,  bait  station,  bait station (s),  block,  briquet,
            briquets, bursts, cake, can, canister, capsule, cartridges, coil, collar, container,  dispenser,  drop,  eartag,  grains,  lure,  pack,  packet,  packets,  pad,  part,
            parts, pellets, piece, pieces, pill, pumps, sec, sec burst, sheet,  spike, stake, stick,  strip,  tab,  tablet,  tablets,  tag,  tape,  towelette,  tray,  unit,  --


  APPLICATION RATE
          :  Dosage Can Not be Calculated
          :  No Calculation can be made
          :  PPM calculated by weight
          :  PPM Calculated by volume
          :  Unknown whether PPM is given by weight or by volume
          :  Hundred Weight
  nnE-xx  :  nn times  (10 power -xx) ; for instance,  "1.234E-04" is equivalent to ".0001234"

  USE LIMITATIONS CODES
  A08 :  Preclean claim.
                                                                                        28

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                                   Report Run  Date:  11/22/95   )   Time 10:53                                          LUIS 2.2 - Page:    5
                                   PRO Report  Date:  04/18/95
                                                                              APPENDIX A REPORT

                                    Case 3033[Busan 74  (*)]                             Chemical 035604[S-(2-Hydroxypropyl)  thiomethanes]
                              444444
USE LIMITATIONS CODES (Cont.)
C18 :  Do not discharge effluent containing this pesticide  into sewage systems without  notifying the sewage treatment plant  authority (POTW).
023 :  NPDES license restriction.
024 :  Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans,  or public water.   (NPDES  license  restriction)
CAH :  Do not discharge into lakes, streams,  ponds, or public water unless in accordance with NPDES Permit.
CAL :  Do not contaminate water, food or feed.
* NUMBER IN PARENTHESES REPRESENTS THE NUMBER OF TIME UNITS (HOURS,DAYS, ETC.) DESCRIBED IN THE LIMITATION.
                                                                                     29

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                               GUIDE TO APPENDIX B
Appendix B contains listings of data requirements which support the reregistration for active
ingredients within the case Hydroxypropyl methanethiosulfonate covered by this Reregistration
Eligibility Decision Document. It contains generic data requirements that apply to Hydroxypropyl
methanethiosulfonate  in all  products,  including  data  requirements for which a  "typical
formulation" is the test substance.

       The data table is organized in the following format:

       1.  Data Requirement (Column 1). The data requirements are listed in the order in which
they appear in 40 CFR Part 158.  the reference numbers accompanying each test refer to the test
protocols set in  the Pesticide Assessment Guidelines, which  are available from  the National
Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703) 487-4650.

       2.  Use Pattern (Column 2). This column indicates the use patterns for which the data
requirements apply. The following letter designations are used for the given use patterns:

                           A     Terrestrial food
                           B     Terrestrial feed
                           C     Terrestrial non-food
                           D     Aquatic food
                           E     Aquatic non-food outdoor
                           F     Aquatic non-food industrial
                           G     Aquatic non-food residential
                           H     Greenhouse food
                           I      Greenhouse non-food
                           J      Forestry
                           K     Residential
                           L     Indoor food
                           M     Indoor non-food
                           N     Indoor medical
                           0     Indoor residential

       3.  Bibliographic citation  (Column 3).  If the Agency has acceptable data in its files, this
column lists the identifying number  of each study.   This normally is the Master  Record
Identification  (MRID)  number,  but may be a "GS" number  if no  MRID number has been
assigned.  Refer  to the  Bibliography appendix for a complete citation of the study.
                                          30

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                    APPENDIX B
Data Supporting Guideline Requirements for the Reregistration of HPMTS
REQUIREMENT
USE PATTERN CITATION(S)
PRODUCT CHEMISTRY
61-1
61-2A
61-2B
62-1
62-2
62-3
63-2
63-3
63-4
63-6
63-7
63-8
63-9
63-12
63-13
63-17
63-20
Chemical Identity
Start. Mat. & Mnfg. Process
Formation of Impurities
Preliminary Analysis
Certification of limits
Analytical Method
Color
Physical State
Odor
Boiling Point
Density
Solubility
Vapor Pressure
PH
Stability
Storage stability
Corrosion characteristics
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M

43420501
43420501
41680902

41680902
41680903
41608903
41680903
41680903
41680903
43420101
42287901
41680903

42766601
42766601
                            31

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         Data Supporting Guideline Requirements for the Reregistration of HPMTS
REQUIREMENT USE PATTERN CITATION(S)
ECOLOGICAL EFFECTS
71-1A
71-2A
71-2B
72-1A
72-1C
72-2A
Acute Avian Oral - Quail/Duck
Avian Dietary - Quail
Avian Dietary - Duck
Fish Toxicity Bluegill
Fish Toxicity Rainbow Trout
Invertebrate Toxicity
F
F
F
F
F
F

41629801, 126121, 126122
249523
41733201
41733203
41733202
TOXICOLOGY
81-1
81-2
81-6
82-3
83-3A
83-3B
84-2A
84-2B
84-4
Acute Oral Toxicity - Rat
Acute Dermal Toxicity - Rabbit/Rat
Dermal Sensitization - Guinea Pig
90-Day Dermal - Rodent
Developmental Toxicity - Rat
Developmental Toxicity - Rabbit
Gene Mutation (Ames Test)
Structural Chromosomal Aberration
Other Genotoxic Effects
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
F,M
41634701
41632401
42349201
40974701
41010501
41010401
40229601
40420201
40420202
OCCUPATIONAL/RESIDENTIAL EXPOSURE
None
Required
                                              32

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	Data Supporting Guideline Requirements for the Reregistration of HPMTS	
 REQUIREMENT                                USE PATTERN                CITATION(S)
 ENVIRONMENTAL FATE
 160-5     Chemical Identity	F,M	43420501	
 161-1     Hydrolysis                                 F        42771801
 RESIDUE CHEMISTRY
 None	Required	
                                           33

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Page Intentionally Blank
              34

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                               GUIDE TO APPENDIX C

1.      CONTENTS OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
       considered relevant by EPA in arriving at the positions and conclusions stated
       elsewhere in the Reregistration Eligibility Document. Primary sources for studies in
       this bibliography have been the body of data submitted to EPA and its predecessor
       agencies in support of past regulatory decisions. Selections from other sources
       including the published literature, in those instances where they have been considered,
       are included.

2.      UNITS OF ENTRY. The unit of entry in this bibliography is called a "study".  In the
       case of published materials, this corresponds closely to an article. In the case of
       unpublished materials submitted to the Agency, the Agency has sought to identify
       documents at a level parallel to the published article from within the typically larger
       volumes in which they were submitted. The resulting "studies" generally have a
       distinct title (or at least a single subject), can stand alone for purposes of review and
       can be described with a conventional bibliographic citation.  The Agency has also
       attempted to  unite basic documents and commentaries upon them, treating them  as a
       single study.

3.      IDENTIFICATION OF ENTRIES.  The entries in this bibliography are sorted
       numerically by Master Record Identifier, or "MRID number".  This number is unique
       to the citation,  and should be used whenever a specific reference is required.  It is not
       related  to the six-digit "Accession Number" which has been used to identify volumes of
       submitted studies (see paragraph 4 (d) (4) below for further explanation).  In a few
       cases, entries added to the bibliography late in the review may be preceded by a nine
       character temporary identifier. These  entries are listed after all MRID entries.  This
       temporary identifying number is also to be used whenever specific reference is needed.

4.      FORM OF ENTRY. In addition to the Master Record Identifier (MRID), each entry
       consists of a citation containing standard elements followed,  in the case of material
       submitted to  EPA, by a description of the earliest known submission.  Bibliographic
       conventions used reflect the standard of the American National Standards Institute
       (ANSI), expanded to provide for certain special needs.

       a     Author.  Whenever the author could confidently be identified, the Agency has
             chosen to show a personal author.  When no individual was identified, the
             Agency has shown an identifiable laboratory or testing facility as the  author.
             When no author or laboratory could be identified, the Agency has shown the
             first submitter as the author.

       b.     Document date.  The date of the study is taken directly from the document.
             When the date is followed by a question mark, the bibliographer has deduced
             the date from the evidence contained in the document.  When the date appears
             as (19??), the Agency was unable to determine or estimate the date of the
             document.

                                           35

-------
c.      Title.  In some cases, it has been necessary for the Agency bibliographers to
       create or enhance a document title.  Any such editorial insertions are contained
       between square brackets.

d.      Trailing parentheses. For studies submitted to the Agency in the past, the
       trailing parentheses include (in addition to any self-explanatory text) the
       following elements describing the earliest known submission:

       (1)    Submission date.  The date of the earliest known submission appears
             immediately following the word "received."

       (2)    Administrative number.   The next element immediately following the
             word "under" is the registration number,  experimental use permit
             number, petition number, or other administrative number associated
             with the earliest known submission.

       (3)    Submitter.  The third  element is the submitter. When authorship is
             defaulted to the submitter, this element is omitted.

       (4)    Volume Identification (Accession Numbers).  The final element in the
             trailing parentheses identifies the EPA accession number of the volume
             in which the original submission of the study appears.  The six-digit
             accession number follows the symbol "CDL," which stands for
             "Company Data Library."  This accession number is in turn followed by
             an alphabetic suffix which shows the relative position of the study within
             the volume.
                                    36

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                               BIBLIOGRAPHY
MRID
CITATION
00126120     Hazleton Raltech, Inc. (1982) Avian Single-dose Oral LD50: Mallard Duck (Anas
             platyrhynchos): Study No. 6026-119.  Final rept. (Unpublished study received Feb
             15,  1983 under 1448-78; submitted by Buckman Laboratories, Inc., Memphis,
             TN; CDL:249523-B)

00126121     Hazleton Raltech, Inc.  (1982) Avian  Dietary LC50: Bobwhite Quail (Colinus
             virginianus): Study No. 6026-121. Final rept.  (Unpublished study received Feb
             15,  1983 under 1448-78; submitted by Buckman Laboratories, Inc., Memphis,
             TN; CDL:249523-C)

00126122     Hazleton Raltech,  Inc.  (1982)  Avian Dietary LC50:  Mallard Duck (Anas
             platyrhynchos): Study No. 6026-120. (Unpublished study received Feb 15, 1983
             under  1448-78;  submitted  by Buckman Laboratories,  Inc.,  Memphis, TN;
             CDL:249523-D)

40229601     Jagannath,   D.R.  [1987]   "Mutagenicity Test  on  HPMTS in  the  Ames
             Salmonella/Microsome Reverse Mutation  Assay", [HLA 9786-0-401];  Hazleton
             Laboratories America, Inc., Kensington, MD; [HED Doc. No. 010670].

40420201     Murli, H. [1987]  "Mutagenicity Test on HPMTS in an In Vitro Sister Chromatid
             Exchange (SCE) Assay Measuring Sister Chromatid Exchange Frequencies in
             Chinese Hamster Ovary (CHO)  Cells", [HLA 9973-0-438]; Hazleton Laboratories
             America, Inc., Kensington, MD; [HED Doc. No.  006594].

40420202     Cifone,  M.A.  [1987]  "Mutagenicity Test on HPMTS in the  Rat Primary
             Hepatocyte Unscheduled DNA Synthesis Assay",  [HLA  9973-0-447];  Hazleton
             Laboratories America, Inc., Kensington, MD; [HED Doc. No. 006594].

40747101     Rodwell, D.E.  [1988]  "Pilot  Teratology Study in Rats with HPMTS",  [SLS
             3138.10]];  Springborn Life Sciences,  Inc.; Spencerville,  OH; [HED Doc. No.
             006920].

40747102     Siglin, J.C. [1988] "Two-Week  Dermal Toxicity  Study in Rats with HPMTS",
             [SLS 3138.8]; Springborn Life Sciences, Inc., Spencerville, OH; [HED Doc. No.
             006920].

40974701     Siglin, J.C., [1988] "91-Day Dermal Toxicity Study in Rats with HPMTS", [SLS
             3138.9]; Springborn Life Sciences, Inc., Spencerville,  OH;  [HED Doc.  No.
             007483].
                                        37

-------
                               BIBLIOGRAPHY
MRID
CITATION
41010401     Rodwell,  D.E.  [1988]  "Teratology Study  in  Rabbits with HPMTS",  [SLS
             3138.13]; Springborn Life Sciences, Inc., Spencerville,  OH; [HED Doc.  No.
             007453].

41010501     Rodwell,  D.E. [1988] "Pilot Teratology Study in Rabbits with HPMTS",  [SLS
             3138.12], Springborn Life Sciences, Inc., Spencerville,  OH; [HED Doc.  No.
             006984].

41010501     Rodwell, D.E. [1988] "Teratology Study in Rats with HPMTS",  [SLS 3138.11];
             Springborn Life Sciences, Inc., Spencerville, OH;  [HED Doc. No. 007453].

41632401     Glaza, S. M.  [1990] "Acute Dermal Toxicity of HPMTS in Rabbits", [HLA 0060-
             5-263]; Hazleton Laboratories America, Inc.,  Madison,  WI; [HED Doc.  No.
             010670].

41634701     Glaza, S. M.  [1990] "Acute Oral Toxicity of HPMTS in Rats" [HLA 0060-5-262];
             Hazleton Laboratories America, Inc., Madison, WI; [HED Doc. No. 010670].

41733201     Ward,  G. (1990) 2-Hydrocypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to Bluegill, Lepomis macrochirus, Under Flow-through Test Conditions:
             Lab Project  Number: J9007018C.   Unpublished study  prepared by  Toxikon
             Environmental Sciences.  37 p.

41733202     Ward,  G. (1990) 2-Hydroxypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to the Water Flea, Daphnia magna, under Flow-through Test Conditions:
             Lab Project  Number: J9007018B.   Unpublished study  prepared by  Toxikon
             Environmental Sciences.  38 p.

41733203     Ward,  G. (1990) 2-Hydroxypropyl  methanethiolsulfonate (HPMTS):  Acute
             Toxicity to Rainbow Trout,  Oncorhynchus mykiss,  under Flowthrough Test
             Conditions: Lab Project Number: J9007018D.   Unpublished study prepared by
             Toxikon Environmental Sciences. 38 p.

42349201     Karcher,  R.,  Siglin,  J.C.   and  Becci,   P.C.   [1986]  "Delayed  Contact
             Hypersensitivity Study in Guinea Pigs with HPMTS", [SIB 3138.7]; Springborn
             Institute for Bioresearch, Inc., Spencerville, OH; [HED Doc. No. 009690].

42771801     Mao, J. (1993) HPMTS-Determination of Aqueous Hydrolysis Rate Constants and
             Half-Lives: Lab Project Number: 995.0292.6138.715: 93-3-4668.  Unpublished
             study prepared by Springborn Labs, Inc. 76  p.
                                        38

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                               BIBLIOGRAPHY

MRID                        CITATION
            Doyle,  E.  [1995]   "Less  than  Lifetime/Peer  Review  Report of  [S-(2-
            hydroxypropyl)thiomethane sulfonate]", Internal U.S. EPA memorandum, [Doyle
            to Aikens].

            Ghali,   G.Z.  [1995]  "RfD/Peer  Review  Report  of  Busan  74  [S-(2-
            hydroxypropyl)thiomethane sulfonate]", Internal U.S. EPA memorandum, [Ghali
            to Swindell,  2/15/95].

            Whalan, J.E., "Policy on Acute Inhalation Toxicity Data Waivers", Internal U.S.
            EPA memo,  Nov. 27, 1991 [Fenner-Crisp to Lindsay], 12/8/91.
DRAFT:EPA:OPP:HED:RCAB:AMAikens: 8/18/95: Revised (TOX 81-3) 8/22/95: Revised
(TOX CATEGORY 81-4  and 81-5; addition of OREB  provisional statements/ contractor)
8/29/95: Edited/RCAB 8/31/95: Final for OD review 9/5/95: Edited  9/15/95: Edited to include
OREB/S. McDonald comments received this date 9/19/95: Revised 9/22/95.
                                       39

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                      BIBLIOGRAPHY




MRID                 CITATION
                            40

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                      WASHINGTON, D.C.  20460
                                                                           OFFICE OF
                                                                     PREVENTION, PESTICIDES
                                                                     AND TOXIC SUBSTANCES
                               DATA CALL-IN NOTICE
CERTIFIED MAIL
Dear Sir or Madam:
This Notice requires you and other registrants of pesticide products containing the active
ingredient identified in Attachment 1 of this Notice, the Data Call-in Chemical Status Sheet, to
submit certain product specific data as noted herein to the U.S. Environmental Protection
Agency (EPA, the Agency).  These data are necessary to maintain the continued registration of
your product(s)  containing this active ingredient.  Within 90 days after you receive this Notice
you must respond as set forth in Section III  below.  Your response must state:

       1.     How you will comply with the requirements set forth in this Notice and its
             Attachments 1 through 6;  or

       2.     Why you believe you are exempt from the requirements listed in this Notice and
             in Attachment 3, Requirements  Status and Registrant's Response Form, (see
             section III-B);  or

       3.     Why you believe EPA should not require your submission  of product specific
             data in the manner specified by this Notice (see section III-D).

       If you do not respond to this Notice, or if you do not satisfy EPA that you will comply
with its requirements or should be exempt or excused from doing so, then the registration of


                                          41

-------
your product(s) subject to this Notice will be subject to suspension.  We have provided a list of
all of your products subject to this Notice in Attachment 2, Data Call-In Response Form, as
well as a list of all registrants who were sent this Notice (Attachment 6).

       The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide
and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B).  Collection of this
information is  authorized under the Paperwork Reduction Act by OMB Approval No. 2070-
0107 and 2070-0057 (expiration date 03-31-96).

       This Notice is divided into six sections and six Attachments. The Notice itself contains
information and instructions applicable to all Data Call-in  Notices. The Attachments contain
specific chemical information and instructions. The six sections of the Notice are:

       Section I  -  Why You Are Receiving This Notice
       Section II  -   Data Required By This Notice
       Section III -   Compliance With  Requirements Of This Notice
       Section IV -   Consequences Of  Failure To  Comply With This Notice
       Section V  -   Registrants'  Obligation To  Report Possible Unreasonable Adverse
                    Effects
       Section VI -   Inquiries And Responses To This  Notice

The Attachments to this Notice are:

       1 -    Data Call-In Chemical Status Sheet
       2 -    Product-Specific Data Call-In Response Form
       3 -    Requirements Status and Registrant's Response Form
       4 -    EPA Batching of End-Use Products for Meeting  Acute Toxicology Data
              Requirements for Reregistration
       5 -    List of Registrants  Receiving This Notice
       6 -    Cost Share and  Data Compensation Forms
SECTION I.  WHY YOU ARE RECEIVING THIS NOTICE

       The Agency has reviewed existing data for this active ingredient and reevaluated the
data needed to support continued registration of the subject active ingredient.  The Agency has
concluded that the only additional data necessary are product specific data.  No additional
generic data requirements are being imposed. You have been sent this  Notice because you
have product(s) containing the subject active ingredient.

SECTION II.  DATA REQUIRED BY THIS NOTICE

II-A.  DATA REQUIRED

       The product specific data required by this Notice are specified in Attachment 3,
Requirements Status and Registrant's Response Form.  Depending on the results of the studies
required in this Notice, additional testing may be required.

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II-B. SCHEDULE FOR SUBMISSION OF DATA

   You are required to submit the data or otherwise satisfy the data requirements specified in
Attachment 3, Requirements Status and Registrant's Response Form, within the time frames
provided.

II-C. TESTING PROTOCOL

   All studies required under this Notice must be conducted in accordance with test standards
outlined in the Pesticide Assessment Guidelines for those studies for which guidelines have been
established.

       These EPA Guidelines are available from the National Technical Information Service
(NTIS), Attn: Order Desk, 5285 Port Royal Road, Springfield, Va 22161 (tel: 703-487-4650).

       Protocols approved by the Organization for Economic Cooperation and Development
(OECD) are also acceptable if the OECD-recommended test standards conform to those specified
in the Pesticide Data Requirements regulation (40 CFR § 158.70).  When using the OECD
protocols, they should be modified as appropriate so that the data generated by the study will
satisfy  the requirements of 40 CFR § 158.  Normally,  the Agency will not extend deadlines for
complying with data requirements when the studies were not conducted in accordance with
acceptable  standards.  The OECD protocols are available from OECD, 2001 L Street, N.W.,
Washington, D.C. 20036 (Telephone number 202-785-6323;  Fax telephone number 202-785-
0350).

       All new studies and proposed protocols submitted in response to this Data Call-in Notice
must be in  accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)].

II-D. REGISTRANTS RECEIVING PREVIOUS SECTION 3(c)(2)(B) NOTICES
     ISSUED BY THE AGENCY

     Unless otherwise noted herein, this Data Call-In does not in any way supersede or change the
requirements of any previous Data Call-In(s), or any other agreements entered into with the
Agency pertaining to such prior Notice.  Registrants must comply with the  requirements of all
Notices to avoid issuance of a Notice of Intent to Suspend their affected products.

SECTION  III.  COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

III-A.  SCHEDULE FOR RESPONDING TO THE AGENCY

       The appropriate responses initially required by this Notice for product specific data must
be submitted to the Agency within 90 days after your receipt of this Notice. Failure to adequately
respond to  this Notice within 90  days of your receipt will be a basis for issuing a Notice of Intent
to Suspend (NOIS) affecting your products. This and other bases for issuance of NOIS due to
failure  to comply with this Notice are presented in Section IV-A and IV-B.

III-B. OPTIONS FOR RESPONDING TO THE AGENCY

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       The options for responding to this Notice for product specific data are:  (a) voluntary
cancellation,  (b) agree to satisfy the product specific data requirements imposed by this notice or
(c) request a data waiver (s).

       A discussion of how to respond if you chose the Voluntary Cancellation option is
presented  below. A discussion of the various options available for satisfying the product specific
data requirements of this Notice is contained in Section III-C. A discussion of options relating to
requests for data waivers is contained in Section III-D.

       There are two forms that accompany this Notice of which, depending upon your response,
one or both must be used in your response to the Agency. These  forms are the Data-Call-in
Response Form, and the Requirements  Status and Registrant's Response Form, Attachment 2 and
Attachment 3. The Data Call-in Response Form must be submitted as part of every response to
this Notice.  In addition, one copy of the Requirements Status and Registrant's Response Form
must be submitted for each product listed on the Data Call-In Response Form unless the voluntary
cancellation option is selected or unless the product is identical to another  (refer to the instructions
for completing the Data Call-In Response Form in Attachment 2). Please note that the company's
authorized representative is required  to sign the first page of the Data Call-In Response Form and
Requirements Status and Registrant's Response Form (if this form is required)  and initial any
subsequent pages. The forms contain separate detailed instructions on the response options. Do
not alter the printed material.  If you have questions or need assistance in preparing your
response,  call or write the contact person(s) identified in Attachment 1.

       1. Voluntary Cancellation - You may avoid the requirements of this Notice by requesting
voluntary  cancellation  of your product(s)  containing the active ingredient that is the subject of this
Notice. If you wish to voluntarily cancel your product, you must submit a completed Data Call-In
Response Form, indicating your election of this option.  Voluntary cancellation is item number 5
on the Data Call-In Response Form. If you choose this  option, this is the only form that you are
required to complete.

       If you chose to voluntarily cancel your  product, further sale and distribution of your
product after  the effective date of cancellation must be in accordance with  the Existing Stocks
provisions of this Notice which are contained in Section IV-C.
       2. Satisfying the Product Specific Data Requirements of this Notice  There are various
options available to satisfy the product specific data requirements of this Notice.  These options
are discussed in Section III-C of this Notice and comprise options 1 through 6 on the
Requirements Status and Registrant's Response Form and item numbers 7a  and 7b on the Data
Call-in Response Form. Deletion of a use(s) and the low volume/minor use option are not valid
options for fulfilling product specific data requirements.

       3. Request  for Product Specific Data Waivers.  Waivers for product specific  data are
discussed in Section III-D of this Notice and are covered by option 7  on the Requirements Status
and Registrant's Response Form. If you choose one of these options, you must submit both forms
as well as any other information/data pertaining to the option chosen  to address the data
requirement.

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III-C  SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

       If you acknowledge on the Data Call-In Response Form that you agree to satisfy the
product specific data requirements (i.e. you select item number 7a or 7b), then you must select
one of the six options on the Requirements Status and Registrant's Response Form related to data
production for each data requirement.  Your option selection should be entered under item
number 9,  "Registrant Response."  The six options  related to data production are the first six
options discussed under item 9 in the instructions for completing the Requirements Status and
Registrant's Response Form.  These six options are listed immediately below with information in
parentheses to guide registrants to additional instructions provided in this Section. The options
are:

       (1)     I will generate and submit data within the specified time frame (Developing Data)
       (2)     I have entered into an agreement with one or more registrants to develop data
             jointly (Cost Sharing)
       (3)     I have made offers to cost-share  (Offers to Cost Share)
       (4)     I am submitting an existing study that has not been submitted previously to the
              Agency by anyone (Submitting an Existing Study)
       (5)     I am submitting or citing data to upgrade a study classified by EPA as partially
              acceptable and upgradeable (Upgrading a Study)
       (6)     I am citing an existing study that EPA has classified as acceptable or an existing
              study that has been submitted but not reviewed by the Agency (Citing an Existing
              Study)

       Option 1, Developing Data — If you choose  to develop the required  data it must be in
conformance with Agency deadlines and with other Agency requirements as referenced herein and
in the attachments.  All data  generated and submitted must comply with the Good Laboratory
Practice (GLP) rule (40  CFR Part 160), be conducted according to the Pesticide Assessment
Guidelines (PAG), and be in conformance with the requirements of PR Notice 86-5.

       The time frames in the Requirements Status  and Registrant's Response Form are the time
frames that the Agency is allowing for the submission of completed study reports. The noted
deadlines run from the date of the receipt of this Notice by the registrant. If the data are not
submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to Suspend the
affected registration(s).

       If you cannot submit the data/reports to the Agency in the time required by this Notice and
intend to seek  additional time to meet the requirements(s), you must submit a request to the
Agency which includes:  (1)  a detailed description of the expected difficulty and (2)  a proposed
schedule including alternative dates for meeting such requirements on a step-by-step basis.  You
must explain any technical or laboratory difficulties and provide  documentation from the
laboratory performing the testing.  While EPA  is considering your request,  the original deadline
remains. The  Agency will respond to your request  in writing. If EPA does not grant your
request, the original deadline remains.  Normally, extensions can be requested  only in  cases of
extraordinary testing problems beyond the expectation or control of the registrant. Extensions
will not be given in submitting the 90-day responses.  Extensions will not be considered if the
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request for extension is not made in a timely fashion; in no event shall an extension request be
considered if it is submitted at or after the lapse of the subject deadline.

       Option 2, Agreement to Share in Cost to Develop Data  — Registrants may only choose
this option for acute toxicity data and certain efficacy data and  only if EPA has indicated in the
attached data tables that your product and at least one other product are similar for purposes of
depending on the same data.  If this is the case, data may be generated for just one of the products
in the group. The registration number of the product for which data will be submitted must be
noted in the agreement to cost share by the registrant selecting  this option. If you choose to enter
into an agreement to share in the cost of producing the required data but will not be submitting
the data yourself, you must provide the name  of the registrant who will be submitting the data.
You must also provide EPA with documentary evidence that an agreement has been formed.  Such
evidence may be your letter offering to join in an agreement and the other registrant's acceptance
of your offer, or a written statement by the parties that an agreement exists.  The agreement to
produce the data need not specify all of the terms of the final arrangement between the parties or
the mechanism  to resolve the  terms.  Section 3(c)(2)(B) provides that if the parties cannot resolve
the terms  of the agreement they may resolve their differences through binding arbitration.

       Option 3, Offer to Share  in  the Cost of Data Development — This option only applies  to
acute  toxicity and certain efficacy data as described in option 2 above.  If you have made an offer
to pay in an attempt to enter into an agreement or amend an existing agreement to meet the
requirements of this Notice and have been unsuccessful, you may request EPA (by selecting this
option) to exercise its discretion not to suspend your registration(s), although you do not comply
with the data submission requirements of this  Notice. EPA has determined that as a general
policy, absent other relevant considerations, it will not suspend the registration of a product of a
registrant who has in good  faith  sought and continues to seek to enter into a joint data
development/cost sharing program, but the  other registrant(s) developing the data has refused to
accept your offer.  To qualify for this option,  you must submit documentation to  the Agency
proving that you have made an offer to another registrant (who has an obligation to submit data)
to share in the burden of developing that data.  You must also submit to the Agency a completed
EPA Form 8570-32,  Certification of Offer to  Cost Share in the Development of Data, Attachment
7. In addition,  you must demonstrate that the other registrant to whom  the offer was made has
not accepted your offer to enter into a cost sharing agreement by including a copy of your offer
and proof of the other registrant's receipt of that offer (such as  a certified mail receipt). Your
offer must, in addition to anything  else, offer  to share in the burden of producing the data upon
terms to be agreed or  failing agreement to be  bound by binding arbitration as provided by FIFRA
section 3(c)(2)(B)(iii) and must not qualify this offer.   The other registrant must also inform EPA
of its  election of an option to  develop and submit the data required by this Notice by submitting a
Data Call-In Response Form and a  Requirements Status and Registrant's Response Form
committing to develop and  submit the data required by this Notice.

       In order for you to avoid suspension under this option, you may not withdraw your  offer
to share in the burdens of developing the data. In addition, the other registrant must fulfill its
commitment to  develop and submit the data as required by this Notice.  If the  other registrant fails
to develop the data or for some other reason is subject to suspension, your registration as well as
that of the other registrant will normally be subject to initiation of suspension proceedings,  unless
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you commit to submit, and do submit the required data in the specified time frame.  In such cases,
the Agency generally will not grant a time extension for submitting the data.

       Option 4, Submitting an Existing Study — If you choose to submit an existing study in
response to this Notice, you must determine that the study satisfies the requirements imposed by
this Notice.  You may only submit a study that has not been previously submitted to the Agency
or previously cited by anyone.  Existing studies are studies which predate issuance of this Notice.
Do not use this option if you are submitting data to upgrade a study. (See Option 5).

       You should be aware that if the Agency determines that the study is not acceptable, the
Agency will require you to comply with this Notice, normally without an extension of the
required date of submission.  The Agency may determine at any time that a study is not valid and
needs to be repeated.

       To meet the requirements of the DCI Notice for submitting an existing study, all of the
following three criteria must be clearly met:

       a.     You must certify at the time that the existing study is submitted that the raw data
              and  specimens from the study are available for audit and review and you must
              identify where they are available.  This must be done in accordance with the
              requirements of the Good Laboratory Practice (GLP) regulation, 40 CFR Part 160.
              As stated in 40 CFR 160.3(j) "  'raw data'  means any laboratory worksheets,
              records, memoranda, notes, or  exact copies thereof, that are the result of original
              observations and activities of a  study and are necessary for the reconstruction and
              evaluation of the report of that  study.  In the event that exact transcripts of raw
              data have been prepared (e.g.,  tapes which have been transcribed verbatim, dated,
              and  verified accurate by signature), the exact copy or exact transcript may be
              substituted for the original source as raw data.  'Raw data' may include
              photographs, microfilm or microfiche copies, computer printouts, magnetic media,
              including dictated observations, and recorded data from automated instruments."
              The term "specimens",  according to 40 CFR 160.3(k), means "any material
              derived from a test system for examination or analysis."

       b.     Health and  safety studies completed after May 1984 must also contain all GLP-
              required quality assurance and  quality  control information, pursuant to the
              requirements of 40 CFR Part 160.  Registrants must also certify at the time of
              submitting the  existing study that such GLP information is available for post-May
              1984 studies by including an appropriate statement on or attached to the study
              signed by an authorized official or representative of the registrant.

       c.     You must certify that each study fulfills the acceptance criteria for the Guideline
              relevant to the study provided in the FIFRA Accelerated Reregistration Phase 3
              Technical Guidance and that the study has been conducted according to the
              Pesticide Assessment Guidelines (PAG) or meets the purpose of the PAG (both
              available from NTIS).  A study not conducted according to the PAG may be
              submitted to the Agency for consideration if the registrant believes that the study
              clearly meets the purpose of the PAG.  The registrant is referred to 40  CFR 158.70

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              which states the Agency's policy regarding acceptable protocols. If you wish to
              submit the study, you must, in addition to certifying that the purposes of the PAG
              are met by the study, clearly articulate the rationale why you believe the study
              meets the purpose of the PAG, including copies of any supporting information or
              data.  It has been the Agency's experience that studies completed prior to January
              1970 rarely satisfied the purpose of the PAG and that necessary raw data are
              usually not available for such studies.
       If you submit an existing study, you must certify that the study meets all requirements of
the criteria outlined above.

       If you know of a study pertaining to any requirement in this Notice which does not meet
the criteria outlined above but does contain factual information regarding unreasonable adverse
effects, you must notify the Agency of such a study.  If such study is in the Agency's files, you
need only cite it along with the notification. If not in the Agency's files, you must submit a
summary and copies as required by PR Notice 86-5.

       Option 5, Upgrading a Study — If a study has  been classified as partially acceptable and
upgradeable, you may submit data to upgrade that study. The Agency will review the data
submitted and determine if the requirement is satisfied.  If the Agency decides the requirement is
not satisfied, you may still be required to submit new data normally without any time extension.
Deficient, but upgradeable studies will normally be classified as supplemental. However, it is
important to note that not all studies classified as supplemental are upgradeable.  If you have
questions regarding the classification of a study or whether a study may be upgraded, call or write
the contact person listed in Attachment 1.  If you submit data to upgrade an existing study you
must satisfy or supply information to correct all deficiencies in the study identified by EPA.  You
must provide a clearly articulated rationale of how the deficiencies have been remedied or
corrected and why the study should be rated as acceptable to EPA.  Your submission must also
specify the MRID number(s) of the study which you are attempting to upgrade and must be in
conformance with PR Notice 86-5.

       Do not submit additional data for the purpose  of upgrading a study classified as
unacceptable and determined by the Agency as not capable of being upgraded.

       This option should also be used to cite data that  has been previously submitted to upgrade
a study, but has not yet been reviewed by the Agency.  You must provide  the MRID number  of
the data submission as well as the MRID number of the study  being upgraded.

       The criteria for submitting an existing study, as  specified in Option 4 above, apply to  all
data submissions intended to upgrade studies. Additionally your submission of data intended  to
upgrade studies must be accompanied by a certification  that you comply with each of those
criteria as well as a certification regarding  protocol compliance with Agency requirements.

       Option 6, Citing Existing Studies — If you choose to cite a study that has been previously
submitted to EPA,  that study must have been previously classified by EPA as acceptable or it
must be a study which has not yet been reviewed by the Agency.  Acceptable toxicology studies

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generally will have been classified as "core-guideline" or "core minimum." For all other
disciplines the classification would be "acceptable."  With respect to any studies for which you
wish to select this option you must provide the MRID number of the study you are citing and, if
the study has been reviewed by the Agency, you must provide the Agency's classification of the
study.

       If you are  citing a study of which you are not the original data submitter, you must submit
a completed copy  of EPA Form 8570-31, Certification with Respect to Data Compensation
Requirements.

       Registrants who select one of the above 6 options must meet all of the requirements
described in the instructions for completing the Data Call-in Response Form and the Requirements
Status and Registrant's Response  Form, as appropriate.

III-D  REQUESTS FOR DATA WAIVERS

             If you request a waiver for product specific data because you believe it is
inappropriate, you must attach a complete justification for the request, including technical
reasons, data and  references to relevant EPA regulations, guidelines or policies. (Note: any
supplemental data must be submitted in the format required by PR Notice 86-5). This will be the
only opportunity to state the reasons or provide information in support of your  request.  If the
Agency approves your waiver request, you will not be required to supply the data pursuant to
section 3(c)(2)(B)  of FIFRA. If the Agency denies your waiver request, you must choose an
option for meeting the data requirements of this Notice within 30 days of the receipt of the
Agency's decision. You must indicate and submit the option chosen on the Requirements Status
and Registrant's Response Form.  Product specific data requirements for product chemistry, acute
toxicity and efficacy (where appropriate) are required for all products  and the Agency would grant
a waiver only under extraordinary circumstances.  You should also be aware that submitting a
waiver request will not automatically extend the due date for  the study in question.  Waiver
requests submitted without adequate supporting rationale will be denied and the original due date
will remain in force.

IV. CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

IV-A NOTICE OF INTENT TO SUSPEND

       The Agency may issue a Notice of Intent to Suspend products subject to this Notice due  to
failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant to
FIFRA section 3(c)(2)(B).  Events which may be the basis for issuance of a Notice of Intent to
Suspend include, but are not limited to, the following:

       1.     Failure to respond as required by this Notice within 90  days of your receipt of this
             Notice.

       2.     Failure to submit on the required schedule an acceptable proposed or final protocol
             when such is required to be submitted to the Agency for review.
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       3.     Failure to submit on the required schedule an adequate progress report on a study
             as required by this Notice.

       4.     Failure to submit on the required schedule acceptable data as required by this
             Notice.

       5.     Failure to take a required action or submit adequate information pertaining to any
             option chosen to address the data requirements (e.g., any required action or
             information pertaining to submission or citation of existing studies or offers,
             arrangements, or arbitration on the sharing of costs or the formation of Task
             Forces, failure to comply with the terms of an agreement or arbitration concerning
             joint data development or failure to comply with any terms of a data waiver).

       6.     Failure to submit supportable certifications as to the conditions  of submitted
             studies, as required by Section III-C of this Notice.

       7.     Withdrawal of an offer to share in the cost of developing required data.

       8.     Failure of the registrant to whom you have tendered an offer to share in the cost of
             developing data and provided proof of the registrant's receipt of such offer or
             failure of a registrant on whom you rely for a generic data exemption either to:

             a.     inform EPA of intent to develop and submit the data required by this Notice
                    on a Data Call-in Response Form  and a Requirements Status and
                    Registrant's Response Form;

             b.     fulfill the commitment to develop  and submit the data as required by this
                    Notice; or

             c.     otherwise take appropriate steps to meet the requirements stated in this
                    Notice, unless you commit to submit  and do submit the required data in  the
                    specified time frame.

       9.     Failure to take any required or appropriate steps, not mentioned above, at any time
             following the issuance of this Notice.

IV-B.  BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS
UNACCEPTABLE

       The Agency may determine that a study (even if submitted within the required time) is
unacceptable and constitutes a basis for issuance of a Notice of Intent to Suspend.  The grounds
for suspension include, but are not limited to,  failure to  meet any of the following:

       1.  EPA requirements specified in the Data Call-In Notice or other documents incorporated
       by reference  (including, as applicable,  EPA Pesticide Assessment Guidelines, Data
       Reporting Guidelines, and GeneTox Health Effects Test Guidelines) regarding the design,
       conduct, and reporting of required studies.  Such requirements include, but are not limited

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       to, those relating to test material, test procedures, selection of species, number of animals,
       sex and distribution of animals, dose and effect levels to be tested or attained, duration of
       test, and, as applicable, Good Laboratory Practices.

       2.  EPA requirements regarding the submission of protocols, including the incorporation
       of any changes required by the Agency following review.

       3.  EPA requirements regarding the reporting of  data, including the manner of reporting,
       the completeness of results, and the adequacy of  any required supporting (or raw) data,
       including, but not limited to, requirements referenced or included in this Notice  or
       contained in PR 86-5. All studies must be submitted in the form of a final report; a
       preliminary report will not be considered to fulfill the submission requirement.

IV-C EXISTING STOCKS OF SUSPENDED OR CANCELLED PRODUCTS

       EPA has statutory  authority to permit continued sale, distribution and use of existing
stocks of a pesticide product which has been suspended or cancelled if doing so would be
consistent with the purposes of the Act.

       The Agency has determined that such disposition by registrants of existing stocks for a
suspended registration when a section 3(c)(2)(B) data request is outstanding would generally not
be consistent with  the Act's purposes.  Accordingly, the Agency anticipates granting registrants
permission to sell, distribute, or use existing stocks of suspended product(s) only in exceptional
circumstances. If you believe such disposition of  existing stocks of your product(s) which may be
suspended for failure to comply with this Notice should  be permitted, you have the burden of
clearly demonstrating to EPA that granting such permission would be consistent with the Act. You
must also  explain why an  "existing stocks" provision is necessary, including  a statement of the
quantity of existing stocks and your estimate of the time  required for their sale, distribution, and
use.  Unless you meet this burden the Agency will not consider any  request pertaining to the
continued sale, distribution,  or use of your existing stocks after suspension.

       If you request a voluntary cancellation of your product(s) as a response to this Notice and
your product is in  full compliance with all Agency requirements, you will have, under most
circumstances, one year from the date your 90 day response to this Notice is due,  to sell,
distribute, or use existing  stocks.  Normally, the Agency will allow persons other  than the
registrant  such as independent distributors, retailers and  end users to sell, distribute or use such
existing stocks until the stocks are exhausted. Any sale, distribution or use of stocks of
voluntarily cancelled products containing an active ingredient for which the Agency has particular
risk concerns will be determined on case-by-case basis.
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       Requests for voluntary cancellation received after the 90 day response period required by
this Notice will not result in the Agency granting any additional time to sell, distribute, or use
existing stocks beyond a year from the date the 90  day response was due unless you demonstrate
to the Agency that you are in full compliance with  all Agency requirements, including the
requirements of this Notice. For example, if you decide to voluntarily cancel your registration six
months before a 3 year study is scheduled to be submitted, all progress reports and other
information necessary to establish that you have been conducting  the study in an acceptable and
good faith manner must have been submitted to the Agency, before EPA will consider granting an
existing stocks provision.

SECTION V. REGISTRANTS'  OBLIGATION TO REPORT POSSIBLE
UNREASONABLE ADVERSE EFFECTS

       Registrants are reminded  that FIFRA section 6 (a) (2) states that if at any time after a
pesticide is registered a registrant has additional factual information regarding unreasonable
adverse effects on the environment by the pesticide, the registrant shall submit the information to
the Agency.  Registrants must notify the Agency of any factual information they have, from
whatever source, including but not limited to interim or preliminary results of studies, regarding
unreasonable adverse effects on man or the environment. This requirement continues as long as
the products are registered by the Agency.

SECTION VI.  INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding the requirements and procedures established by this
Notice,  call the contact person(s) listed in Attachment 1, the Data Call-In Chemical Status Sheet.
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       All responses to this Notice (other than voluntary cancellation requests and generic data
exemption claims) must include a completed Data Call-in Response Form and a completed
Requirements Status and Registrant's Response Form (Attachment 2 and Attachment 3 for product
specific data) and any other documents required by this Notice, and should be submitted to the
contact person(s) identified in Attachment 1.  If the voluntary cancellation or generic data
exemption option is chosen, only the Data Call-in Response Form need be submitted.

       The Office of Compliance Monitoring (OCM) of the Office of Pesticides and Toxic
Substances  (OPTS), EPA, will be monitoring the data being generated in response to this Notice.

                                        Sincerely yours,
                                        Lois Rossi, Division Director
                                        Special Review and
                                         Reregistration Division
Attachments

       1  -   Data Call-in Chemical Status Sheet
       2  -   Product-Specific Data Call-in Response Form
       3  -   Requirements Status and Registrant's Response Form
       4  -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5  -   List of Registrants Receiving This Notice
       6  -   Cost Share and Data Compensation Forms and the Confidential Statement of
             Formula Form
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HYDROXYPROPYL METHANETHIOSULFONATE DATA CALL-IN CHEMICAL STATUS
SHEET

INTRODUCTION

       You have been sent this Product Specific Data Call-In Notice because you have product(s)
containing Hydroxypropyl methanethiosulfonate.

       This Product Specific Data Call-In Chemical Status Sheet,  contains an overview of data
required by this notice, and point of contact for inquiries  pertaining to the  reregistration  of
Hydroxypropyl methanethiosulfonate.  This attachment is to be used in conjunction with  (1) the
Product Specific Data  Call-In  Notice, (2) the Product  Specific  Data Call-In Response  Form
(Attachment 2), (3) the Requirements Status and Registrant's Form (Attachment 3), (4)  EPA's
Grouping of End-Use Products for Meeting Acute Toxicology Data Requirement (Attachment 4),
(5)  the  EPA Acceptance  Criteria (Attachment 5), (6) a  list of registrants receiving this DCI
(Attachment 6) and  (7) the Cost  Share  and Data Compensation Forms  in  replying to this
Hydroxypropyl methanethiosulfonate Product Specific Data Call-In (Attachment 7).  Instructions and
guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

       The additional  data  requirements  needed to complete the  database for Hydroxypropyl
methanethiosulfonate  are  contained in the  Requirements Status  and Registrant's Response,
Attachment  3.    The  Agency  has concluded that   additional  data  on  Hydroxypropyl
methanethiosulfonate are needed for specific products. These data are required to be submitted to the
Agency within the time frame listed. These data are needed to fully complete the reregistration  of
all eligible Hydroxypropyl methanethiosulfonate products.

INQUIRIES AND RESPONSES TO THIS NOTICE
      If you have any questions regarding this product specific data requirements and procedures
established by this Notice, please contact Moana Appleyard at (703) 308-8175.

      All responses to this Notice for the Product Specific data requirements should be submitted
      to:
             Moana Appleyard
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch 7508W
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE: Hydroxypropyl methanethiosulfonate


                                          55

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   INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM FOR
                             PRODUCT SPECIFIC DATA

Item 1-4.     Already completed by EPA.

Item 5.       If you wish to voluntarily cancel your product, answer "yes."  If you choose this
             option, you will not have to provide the data required by the Data Call-In Notice and
             you will not have to complete any other forms.  Further sale and distribution of your
             product after the effective date of cancellation must be in accordance with the Existing
             Stocks provision of the Data Call-In Notice (Section IV-C).

Item 6.       Not applicable since this form calls in product specific data only.  However, if your
             product is identical to another product and you qualify for a data exemption, you
             must respond with "yes" to Item 7a (MUP) or 7B  (EUP)  on this form, provide the
             EPA registration  numbers  of your source(s);  you would  not complete the
             "Requirements Status and Registrant's Response" form. Examples of such products
             include repackaged products and Special Local Needs (Section 24c) products which
             are identical to federally registered products.

Item 7a.      For each  manufacturing use product (MUP) for which you wish to maintain
             registration, you must agree to satisfy the data requirements by responding "yes."

Item 7b.      For each end use product (EUP) for which you wish to maintain registration, you
             must agree  to satisfy the data requirements by  responding "yes."  If you are
             requesting a data waiver, answer "yes" here; in addition, on  the "Requirements
             Status and  Registrant's Response" form under Item 9, you must respond with Option
             7 (Waiver  Request) for each study for which you are requesting a waiver. See Item
             6 with regard to identical products and data exemptions.

Items 8-11.  Self-explanatory.

NOTE:       You may provide additional information that does not fit on this form in a signed
             letter that accompanies this form.  For example, you may wish to report that your
             product has already been  transferred to another company or that you have already
             voluntarily canceled this product. For these cases,  please  supply all relevant details
             so that EPA can ensure that its records are correct.
                                           56

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               57

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 INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
         REGISTRANT'S RESPONSE FORM FOR PRODUCT SPECIFIC DATA

Item 1-3      Completed by EPA. Note the unique identifier number assigned by EPA in Item
             3.  This number  must be  used in the transmittal document for  any data
             submissions in response to this Data Call-In Notice.

Item 4.       The  guideline reference numbers of studies  required to support the  product's
             continued registration are identified.  These guidelines, in addition to the requirements
             specified in the Notice, govern the conduct of the required studies. Note that series
             61 and 62 in product chemistry are now listed  under 40 CFR 158.155 through
             158.180,  SubpartC.

Item 5.       The study title associated with the guideline reference number is identified.

Item 6.       The use pattern(s) of the pesticide associated with the product specific requirements
             is (are) identified. For most product specific data requirements, all use patterns are
             covered by the data requirements.  In the case of efficacy data, the required studies
             only pertain to products which have the use sites and/or pests indicated.

Item 7.       The substance to be tested is identified by EPA.  For product  specific data, the
             product as formulated  for sale and distribution is the test substance, except in rare
             cases.

Item 8.       The due date for submission of each study is identified. It is normally based on 8
             months after issuance of the Reregistration Eligibility Document unless EPA
             determines that a longer time period is necessary.

Item 9.       Enter only one of the following response codes for each data requirement to show
             how you intend to comply with the data requirements listed in this table.  Fuller
             descriptions of each option are contained in the Data Call-In Notice.

       1.     I  will generate and submit data by the specified due date  (Developing Data). By
             indicating that I have  chosen  this  option, I certify that I will comply with  all the
             requirements pertaining to the conditions for submittal of this study as outlined in the
             Data Call-In Notice. By the specified due date, I will also submit:  (1) a completed
             "Certification With Respect To Data Compensation  Requirements" form (EPA
             Form  8570-29)  and (2) two  completed and  signed  copies of  the  Confidential
             Statement of Formula (EPA Form 8570-4).

       2.     I have entered into an agreement with one or more registrants to develop data jointly
             (Cost Sharing).  I  am submitting a copy of this agreement.  I understand that this
             option is  available only for acute toxicity or certain efficacy data and only if EPA
             indicates in an attachment to this Notice that my product is similar enough to another
             product to qualify for this option.  I  certify that another party in the agreement  is


                                          58

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       committing to  submit or  provide the required data; if the required study is  not
       submitted on time, my product may be subject to  suspension. By the specified  due
       date, I will also submit:  (1)  a  completed "Certification  With Respect To Data
       Compensation Requirements"  form (EPA Form 8570-29) and (2) two completed
       and signed copies of the Confidential Statement of Formula (EPA Form 8570-4).

3.      I have made offers to share in the cost to develop data (Offers to Cost Share).  I
       understand that this option is available only for acute toxicity or certain efficacy data
       and only if EPA indicates in an attachment to this Data  Call-in Notice that my product
       is similar enough to  another product to qualify for  this option.   I am submitting
       evidence that I have made an offer to another registrant (who has an obligation to
       submit data) to share in the cost of that data.  I am also submitting a completed
       "Certification of Offer to Cost Share in the Development Data" form.  I am
       including a copy of my offer and proof of the other registrant's receipt of that offer.
       I am identifying the party which is committing to submit or provide  the required data;
       if the required study is not submitted  on time,  my product may be subject to
       suspension.  I understand that other terms under Option 3 in the Data Call-in Notice
       (Section III-C.l.) apply as  well.   By the specified due date, I will  also submit: (1) a
       completed "Certification  With Respect To Data Compensation Requirements"
       form  (EPA Form 8570-29) and  (2) two completed  and signed  copies of  the
       Confidential Statement of Formula (EPA Form 8570-4).

4.      By the specified due date, I  will submit an existing study that has not been submitted
       previously to the Agency by anyone (Submitting an Existing Study). I certify that
       this study will meet all the requirements for submittal of  existing data outlined in
       Option 4 in the Data Call-In Notice (Section  III-C.l.) and  will  meet the attached
       acceptance criteria (for acute toxicity and product chemistry data). I will attach the
       needed supporting information along with this response.  I also certify that I have
       determined that this study will fill the data requirement for which I have indicated this
       choice.  By the specified due date, I will also submit a completed "Certification With
       Respect To Data Compensation Requirements" form (EPA Form 8570-29) to
       show what data compensation option I have chosen.  By the specified due date, I will
       also submit: (1) a completed "Certification  With Respect  To Data Compensation
       Requirements" form (EPA Form 8570-29) and (2) two completed and signed copies
       of the Confidential Statement of Formula (EPA Form 8570-4).

5.      By the specified due date,  I will submit or cite data to upgrade a study classified by
       the Agency as partially acceptable and upgradable (Upgrading  a Study). I will
       submit evidence of the Agency's review indicating that the study may be upgraded
       and what information is required to do so.  I will provide  the MRID or Accession
       number of the study at the  due date.  I understand that the conditions for this option
       outlined Option 5  in the  Data  Call-In Notice (Section III-C.l.) apply.  By  the
       specified due date, I will also submit: (1)  a completed "Certification With Respect
       To Data Compensation Requirements"  form (EPA Form 8570-29) and (2) two
                                    59

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             completed and signed copies of the Confidential Statement of Formula (EPA Form
             8570-4).

       6.     By the specified due date, I will cite an existing study that the Agency has classified
             as acceptable or an existing study that has been submitted but not reviewed by the
             Agency  (Citing an Existing Study).  If I am citing another registrant's study, I
             understand that this option is available  only for acute toxicity or certain efficacy data
             and only if the cited study was conducted on my product, an identical product or a
             product which EPA has "grouped" with one or more other products for purposes of
             depending on the same data. I may  also choose this option if I am citing my own
             data.  In either case, I will provide the MRID or Accession number(s) for the cited
             data on  a "Product Specific Data Report" form or in a similar format.  By the
             specified due  date,  I will also submit:  (1) a  completed "Certification With Respect
             To Data Compensation Requirements" form (EPA Form 8570-29)  and (2) two
             completed and signed copies of the Confidential Statement of Formula (EPA Form
             8570-4).

       7.     I request a waiver for this study because it is inappropriate for my product (Waiver
             Request). I am attaching a complete justification for this request, including technical
             reasons, data and  references to relevant EPA regulations, guidelines  or  policies.
             [Note: any supplemental data must be submitted in the format required by  P.R. Notice
             86-5]. I understand that this is my only opportunity to state the reasons or provide
             information in support of my request.  If the Agency approves my waiver request, I
             will not be required to supply the data pursuant to Section 3(c) (2) (B)  of FIFRA. If
             the Agency denies  my waiver request, I must choose a method of meeting the data
             requirements of this Notice by the due date stated by this Notice.  In  this case, I must,
             within 30 days of my receipt of the Agency's written decision,  submit a revised
             "Requirements Status and Registrant's  Response" Form indicating the option chosen.
             I also understand that the deadline for submission of data as specified by the original
             data call-in notice will not change.  By the specified due date, I will also submit: (1)
             a completed "Certification With Respect To Data Compensation Requirements"
             form (EPA  Form 8570-29)  and (2)  two completed and signed copies of the
             Confidential Statement of Formula (EPA Form 8570-4).

Items 10-13.  Self-explanatory.

NOTE:      You may provide additional information  that does not fit on this form in a signed
             letter that accompanies this form.  For example, you may wish to report that your
             product has already been transferred to another company or that  you have already
             voluntarily canceled this product. For these cases, please supply all relevant details
             so that EPA can ensure that its records are  correct.
                                           60

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               61

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               62

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               63

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               64

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EPA'S BATCHING OF HYDROXPROPYLMETHANE THIOSULFONATE (HPMTS)
PRODUCTS FOR MEETING ACUTE TOXICITY DATA REQUIREMENTS FOR
REREGISTRATION

       In an effort to reduce the time, resources and number of animals needed to fulfill the
acute toxicity data requirements for reregistration of products containing HPMTS as the active
ingredient,  the Agency has batched products which can be considered similar for purposes of
acute toxicity. Factors considered in the sorting process include each product's active and inert
ingredients (identity, percent composition and biological activity), type of formulation (e.g.,
emulsifiable concentrate, aerosol, wettable powder, granular, etc.), and labeling (e.g., signal
word, use classification, precautionary labeling, etc.).  Note that the Agency is not describing
batched products as "substantially similar" since some  products within a batch may not be
considered  chemically similar or have identical use patterns.

       Using available information,  batching has been accomplished by the process described in
the preceding paragraph. Notwith-standing the batching process, the Agency reserves the right to
require, at  any time, acute toxicity data for an individual product should the need arise.

       Registrants of products within a batch may choose to cooperatively generate, submit or
cite a single battery of six acute toxicological studies to represent all the products within that
batch. It is  the registrants' option to participate in the process with all other registrants, only
some of the other registrants,  or only their own products within a batch, or to generate  all the
required acute toxicological studies for each of their own products.  If a registrant chooses to
generate the data for a batch, he/she must use one  of the products within the batch as the test
material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she
may do so provided that the data base is complete and  valid by today's standards (see acceptance
criteria  attached), the formulation tested is considered  by EPA to be similar  for acute toxicity,
and the  formulation has not been significantly altered since submission and acceptance of the
acute toxicity data. Regardless of whether new data is  generated or existing data is referenced,
registrants  must clearly identify the test material by EPA Registration Number.  If more than one
confidential statement of formula (CSF) exists for  a product,  the registrant must indicate the
formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow
the directions given in the Data Call-In Notice and its attachments appended to the RED. The
DCI Notice contains two response forms which are to  be completed and submitted to the Agency
within 90 days of receipt.  The first form,  "Data Call-In Response," asks whether the registrant
will meet the data requirements for each product.  The second form, "Requirements Status and
Registrant's Response," lists the product specific data required for each product, including the
standard six acute toxicity tests.  A registrant who wishes to participate in a  batch must decide
whether he/she will provide the data or depend on someone else to do so.  If a registrant supplies
the data to  support a batch of products, he/she must select one of the following options:
Developing Data (Option 1), Submitting an Existing Study (Option 4), Upgrading an Existing
Study (Option 5) or Citing an Existing Study (Option  6). If a registrant depends on another's


                                            65

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data, he/she must choose among: Cost Sharing (Option 2), Offers to Cost Share (Option 3) or
Citing an Existing Study (Option 6). If a registrant does not want to participate in a batch, the
choices  are Options 1, 4, 5 or 6. However, a registrant should know that choosing not to
participate in a batch does not preclude other registrants in the batch from citing his/her studies
and offering to cost share (Option 3) those studies.

       Nine products were found which contain HPMTS as the active ingredient. The  products
have been placed into three batches and a "no batch" category in accordance with the active and
inert ingredients, type of formulation and current labeling. Table 1 identifies the batched
products. Table 2 lists 1 product that was considered not to be similar to any other product and
has been placed in the "no batch" category.

 Table  1
Batch
1

2



3

EPA Reg. No.
1448-31
1448-36
1448-76
1448-77
1448-78
1448-79
1448-27
1448-30
% Active Ingredient
80.0
80.0
25.0
15.0
10.0
5.0
32.0
14.6
Formulation Type
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
 Table 2  (No Batch)
EPA Reg. No.
1448-90
% Active Ingredient
10.0
Formulation Type
Liquid
       The products in Batch 1 are considered technicals and have been reviewed in the RED
Toxicology Chapter.  Data are sufficient to label these products and no additional data needs to
be submitted.  In addition,  as the active ingredient is considered to be a dermal sensitizer, all
products containing this active ingredient should be labeled for dermal sensitization. No
additional dermal sensitization studies need be submitted.  Inhalation toxicity has been waived for
all products also, because the use pattern precludes inhalation exposure.

       There is sufficient information on acute toxicity to label the products in Batch 2 with the
following exceptions:
                                             66

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       A primary dermal irritation study is needed for 1448-76 and 1448-77.  A category III
       result from 1448-76 could be bridged to 1448-77.

       A primary eye irritation study is needed for 1448-79.

For Batch 3, an acute oral and dermal toxicity  study is needed for 1448-27.  Primary dermal and
eye irritation studies are needed for both 1449-27 and 1448-30.

       There is sufficient information on acute toxicity to label 1448-90 with the exception  of the
acute oral toxicity study.  The study on file is inconclusive with regard to the LD50 in female
animals.  The study must be repeated.
                                            67

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               68

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    ATTENTION CRM::: PLEASE NOTE:::
REMOVE THIS PAGE AND INSERT THE LIST OF
    REGISTRANTS RECEIVING THIS DCI
                       69

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Instructions for Completing the Confidential Statement of Formula

The Confidential Statement of Formula (CSF) Form 8570-4 must be used. Two legible, signed
copies of the form are required.  Following are basic instructions:

      a. All the blocks on the form must be filled in and answered completely.

      b.     If any block is not applicable, mark it N/A.

      c.     The CSF must be signed, dated and the telephone number of the responsible party
             must be provided.

      d.     All applicable information which is on the product specific data submission must
             also be reported on the CSF.

      e.     All weights reported under item 7 must be in pounds per gallon for liquids and
             pounds per cubic feet for solids.

      f.     Flashpoint must be in degrees Fahrenheit and flame extension in inches.

      g.     For all active ingredients, the EPA Registration Numbers for the currently
             registered source products must be reported under column 12.

      h.     The Chemical Abstracts Service (CAS)  Numbers for all actives and inerts and all
             common names for the trade names must be reported.

      i.     For the active ingredients, the percent purity of the source products must be
             reported under column 10 and must be exactly the same as on the source product's
             label.
      j.     All the weights in columns 13.a. and 13.b. must be in pounds, kilograms, or
             grams. In no case will volumes be accepted. Do not mix English and metric
             system units (i.e., pounds and kilograms).

      k.     All the items under column  13.b. must total 100 percent.

      1.     All items under columns 14.a. and 14.b. for the active ingredients must represent
             pure active form.

      m.    The upper and lower certified limits for ail active and inert ingredients must follow
             the 40 CFR 158.175 instructions. An explanation must be provided if the proposed
             limits are different than standard certified limits.

      n.     When new CSFs are submitted and approved, all previously submitted CSFs
             become obsolete for that specific formulation.
                                           70

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              72

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    r/EPA
United  States  Environmental  Protection Agency
            Washington,  DC  20460
   CERTIFICATION  OF OFFER TO COST
SHARE  IN THE  DEVELOPMENT  OF DATA
Form Approved

OMB No.  2070-0106
         2070-0057

Approval  Expires  3-31-96
 Public reporting burden for this collection of information is estimated to average 15 minutes per response, including
 time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
 completing and reviewing the collection of information.  Send comments regarding the burden estimate or any other
 aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy
 Branch, PM-223, U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20460; and to the Office
 of Management and Budget,  Paperwork Reduction Project (2070-0106), Washington, DC 20503.

 Please fill in blanks below.
  Company Name
                                                                            Company Number
  Product Name
                                                                            EPA Reg. No.
 I Certify that:

 My company is willing to develop and submit the data required by EPA under the authority of the Federal
 Insecticide, Fungicide and Rodenticide Act (FIFRA), if necessary.  However, my company would prefer to
 enter into an agreement with one or more registrants to develop jointly or share in the cost of developing
 data.

 My firm has offered in writing to enter into such an agreement. That offer was irrevocable and included an
 offer  to be bound by arbitration decision under section 3(c)(2)(B)(iii) of FIFRA if final agreement on all
 terms could not be reached otherwise.  This offer was made to the following firm(s) on the following
 date(s):
  Name of Firm(s)
                                                                             Date of Offer
Certification:
I certify that I am duly authorized to represent the company named above, and that the statements that I have made on
this form and all attachments therein are true, accurate, and complete. I acknowledge that any knowingly false or
misleading statement may be punishable by fine or imprisonment or both under applicable law.
 Signature of Company's Authorized Representative
                                                                            Date
 Name and Title (Please Type or Print)
 EPA Form 8570-32 (5/91)    Replaces EPA Form 8580, which is obsolete
                                                  73

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              74

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                         United States Environmental Protection Agency
                                     Washington, DC 20460
  CERTIFICATION WITH RESPECT TO
DATA COMPENSATION REQUIREMENTS
                                                                               '
                                                                      Form Approved
                                                                      OMB No. 2070-0107,
                                                                      2070-0057
                                                                      Approval Expires
                                                                      3-31-96
  Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for
  reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the
  collection of information.  Send comments regarding the burden estimate or any other aspect of this collection of information,
  including suggestions for reducing this burden to, Chief Information Policy Branch, PM-233, U.S.  Environmental Protection
  Agency, 401 M St., S.W., Washington, DC 20460; and to the Office of Management and Budget,  Paperwork Reduction Project
  (2070-0106), Washington, DC 20503.

  Please fill in blanks below.
Company Name
Product Name
Company Number
EPA Reg. No.
  I Certify that:

  1.    For each study cited in support of registration or reregistratiion under the Federal Insecticide, Fungicide and Rodenticide Act
  (FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the written permission of the original
  data submitter to cite that study.

  2.    That for each study cited in support of registration or reregistration under  FIFRA that is NOT an exclusive use study, I am  the
  original data submitter, or I have obtained the written permission of the original data submitter, or I have notified in writing the
  company(ies) that submitted data I  have cited and have offered to: (a) Pay compensation for those data in accordance with sections
  3(c)(1 )(F) and 3(c)(2)(D) of FIFRA;  and (b) Commence negotiation to determine which data are subject to the compensation
  requirement of FIFRA and the amount of compensation due, if any. The companies I have notified are. (check one)

   [  ] The companies who have submitted the studies listed on the back of this form or attached sheets, or indicated on the attached
  "Requirements Status and Registrants' Response Form,"

  3.    That I  have previously complied with  section 3(c)(1)(F) of FIFRA for the studies I have cited in support of registration or
  reregistration under FIFRA.
Signature
Date
  Name and Title (Please Type or Print)
  GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, with regard to the registration or
  reregistration of my products, to the extent required by FIFRA section 3(c)(1)(F) and 3(c)(2)(D).
Signature
Date
  Name and Title (Please Type or Print)
EPA Form 8570-31 (4-96)
                                                           75

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              76

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    The following is a list of available documents for Hydroxypropyl methanethiosulfonate that
my further assist you in responding to this Reregistration Eligibility Decision document. These
documents may be obtained by the following methods:

Electronic
File format:  Portable Document Format  (.PDF) Requires Adobe® Acrobat  or  compatible
             reader.  Electronic copies can  be downloaded from the Pesticide Special Review
             and Reregistration Information System at 703-308-7224.  They also are available
             on the Internet on EPA's gopher server, GOPHER.EPA.GOV, or using ftp on
             FTP.EPA.GOV, or using WWW (World Wide Web) on WWW.EPA.GOV., or
             contact Moana Appleyard at (703)-308-8175.

    1.        PR Notice 86-5.

    2.        PR Notice 91-2 (pertains to the Label Ingredient Statement).

    3.        A full copy of this RED  document.

    4.        A copy  of the fact sheet  for Hydroxypropyl methanethiosulfonate.


    The  following  documents are  part of the  Administrative Record  for  Hydroxypropyl
methanethiosulfonate and may included in the EPA's Office of Pesticide Programs Public Docket.
Copies of these documents are not available electronically, but may be obtained by contacting the
person listed on the Chemical Status Sheet.

    1.        Health and Environmental Effects Science Chapters.

    2.        Detailed Label Usage Information System (LUIS)  Report.

    The following Agency reference documents are not available electronically, but may be
obtained by contacting the person listed on the  Chemical Status Sheet of this RED document.

    1.        The Label Review Manual.

    2.        EPA Acceptance Criteria
                                          77

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