United States      Prevention, Pesticides     EPA712-C-96-299
          Environmental Protection   and Toxic Substances     February 1996
          Agency        (7101)
&EPA    Microbial Pesticide
          Test Guidelines
          OPPTS 885.2000
          Background for Residue
          Analysis of Microbial
          Pest Control Agents

-------
                           INTRODUCTION
     This guideline is one  of a  series  of test  guidelines that have been
developed by the Office of Prevention, Pesticides and Toxic Substances,
United States Environmental  Protection Agency for use  in the testing of
pesticides and toxic substances, and the  development of test data that must
be submitted to the Agency  for review under Federal regulations.

     The Office of Prevention, Pesticides and Toxic Substances (OPPTS)
has  developed this guideline through  a process of harmonization that
blended the testing  guidance  and requirements that  existed in the Office
of Pollution Prevention and  Toxics  (OPPT) and appeared in Title  40,
Chapter I,  Subchapter R of the Code of Federal Regulations  (CFR),  the
Office of Pesticide Programs (OPP) which appeared in publications of the
National Technical  Information Service (NTIS) and the guidelines pub-
lished by the Organization  for Economic Cooperation and Development
(OECD).

     The purpose of harmonizing these  guidelines  into a single set of
OPPTS guidelines is to minimize  variations among the testing procedures
that must be performed to meet the data  requirements of the U. S. Environ-
mental Protection Agency  under  the Toxic  Substances  Control Act  (15
U.S.C. 2601) and the Federal Insecticide, Fungicide and Rodenticide Act
(7U.S.C. I36,etseq.).

     Final  Guideline Release: This guideline  is available from the U.S.
Government Printing Office, Washington, DC 20402 on The Federal Bul-
letin   Board.   By  modem  dial   202-512-1387,  telnet   and   ftp:
fedbbs.access.gpo.gov    (IP     162.140.64.19),    internet:     http://
fedbbs.access.gpo.gov, or call 202-512-0132 for disks  or paper copies.
This guideline is also available electronically in ASCII and PDF (portable
document format) from the EPA Public Access Gopher  (gopher.epa.gov)
under the heading "Environmental Test  Methods and Guidelines."

-------
OPPTS 885.2000   Background for residue analysis of microbial pest
control agents.
     (a) Scope—(1) Applicability. This guideline is intended to meet test-
ing requirements  of the Federal Insecticide,  Fungicide, and Rodenticide
Act (FIFRA) (7 U.S.C. 136, et seq.).

     (2) Background. The source material used in developing this har-
monized OPPTS test guideline is OPP guideline 153A-l.

     (b) Requirements. A petition for a  tolerance or for  an  exemption
from the requirement of a tolerance must be submitted as specified  in 40
CFR 158.740 in connection with each application for registration of  a mi-
crobial pest control agent (MPCA)  where usage may result in residues
in or on food for humans or feed for domestic animals used for human
food. This petition  must contain data satisfying the requirements of 40
CFR 158.740 which are detailed in OPPTS  885, Group B  (Residue Test
Guidelines) unless specifically exempted from the requirements.

     (c) Purpose. Residue chemistry data  are designed to provide the  in-
formation necessary to determine the site, nature, and magnitude  of resi-
dues in or on food or feed. This information includes plant metabolism
data, residue data,  analytical methodology,  and, when indicated, animal
metabolism  data and animal feeding studies to determine the carry over
of residues into meat, milk, poultry, and eggs.

     (d) Authority.  Pesticides including MPCAs, intended for use on food
or feed crops, or  where usage may reasonably be  expected to result (di-
rectly or indirectly)  in residues in food or  feed, will not be  registered un-
less  a  tolerance, or an exemption from the  requirement of a tolerance,
has been established by the Agency, as provided for under sections 406,
408, or 409 of the  Federal Food, Drug,  and Cosmetic Act  ((FFDCA) 21
U.S.C. 346,  346a, and 348). The procedural regulations for filing petitions
for a tolerance or an exemption are included in 40 CFR 180.7.

     (e) Approach.  The use of an MPCA on food, feed, or raw agricultural
commodities requires that a tolerance, or an exemption from the require-
ment for a tolerance, be established by the  Agency.  In considering exemp-
tions from the requirement for tolerances,  the  Agency  recognizes that
MPCAs do not necessarily pose the same potential hazards as conventional
chemical pesticides. In fact, certain characteristics of many of these agents
suggest that they may pose relatively less hazard. These  characteristics
are listed below:

     (1) The efficacy of the agent often depends upon its  ability to rep-
licate in the target  pest, which is not likely to remain on  the crop after
harvest.

     (2) The living  form of the agent in most instances will usually not
replicate in the absence of the specific target pest (e.g. insect host).

-------
     (3) Certain environmental conditions such as sunlight, rainfall, winds,
humidity, and temperature often greatly reduce the viability of the agent;
therefore, the residues of living organisms are apt to be small or relatively
insignificant shortly after application.

     (4) Data supporting currently  registered  MPCAs indicate that  they
would not likely pose a hazard to humans or other mammals.

     (5) In many instances where and when a microorganism is  used as
an MPCA, the microorganism is already normally present in the environ-
ment and has demonstrated no adverse effects.

     (6) Residues of microorganisms used as MPCAs that are capable of
replication on food or feed—a very remote possibility—may be rendered
nonviable or  be removed by the usual processing of such foods and feeds
(i.e., washing, drying, heat sterilization, and additions of sugar,  salt, and
other preservatives).

     (f) Tier  progression. The Agency evaluates residue data for MPCAs
used on food, feed, or raw agricultural commodities only if toxic or other
harmful properties were observed in the maximum hazard toxicology  tests
(Tier I) prescribed in toxicology test guidelines OPPTS  885.3050  through
885.3650 of this series. If Tier I toxicology tests indicate no toxic or other
harmful properties, then no residue data (with the general exception of
a monitoring method) would be indicated and  thus a recommendation for
an exemption from the requirements of a tolerance can be made.

     (g) General residue data requirements for MPCAs—(1) When re-
quired. Residue data are required by 40 CFR 158.740  to be included in
a petition for a tolerance or for an exemption from the requirement of
a tolerance, in connection with each application for registration of a manu-
facturing-use product  or end-use product composed of or containing  an
MPCA, when the following conditions are met:

     (i) When the product is intended for use  on food or feed crops.

     (ii) When use of the product  is expected to  result in residues in or
on food or feed.

     (iii) When results of Tier I toxicology  studies conducted in accord-
ance with OPPTS  885.3050 through 885.3500 indicate that there  may be
significant human health concerns.

     (iv) Residue data  may not be  required and an exemption from the
requirement of a tolerance may be  recommended for products  intended
for use on food feed  crops  or for uses expected  to  result in  residues in
or on food or feed, when the toxicology data developed from Tier I testing,
in accordance with toxicology test guidelines OPPTS 885.3050  through
885.3650 of this series, indicate that there are no significant human health

-------
concerns.  The exception to  this is that a monitoring method will be re-
quired for each registered MFC A, even if exempt from tolerance.

     (2) Procedures, standards, and reporting. In addition to the provi-
sions set forth in OPPTS 885.0001 that are applicable, the following guid-
ance is provided for conducting, developing, and reporting the residue data
that  the Agency requires to support a petition for a tolerance  or for an
exemption fom the requirement of a tolerance. In general,  the guidance
in OPPTS series 860, particularly in terms of rationale and approach, is
applicable to MPCAs under this subdivision.  Unless addressed below, all
parts of OPPTS series 860 as written are to  be considered  applicable to
this  series OPPTS 885; the  term  "pesticide"  is  assumed to  include
MPCAs. Discussion with appropriate Agency  scientists may be helpful be-
fore  steps are taken to develop residue data of the nature outlined in this
series.

-------