United
States
Prevention,
Pesticides
EPA
OPP­
2006­
XXX
Environmental
Protection
And
Toxic
Substances
June
XX,
2006
Agency
(
7508P)

______________________________________________________________
_____

Reregistration
Eligibility
Decision
for
Pentachloronitrobenzene
List
A
Case
No.
0128
CERTIFIED
MAIL
Dear
Registrant:

The
Environmental
Protection
Agency
(
EPA,
or
the
Agency)
has
completed
its
review
of
the
available
data
and
public
comments
received
related
to
the
risk
assessments
for
the
organochlorine
fungicide,
pentachloronitrobenzene,
or
PCNB.
Based
on
this
review,
we
have
made
a
determination
that
many
of
the
uses
of
PCNB
are
not
eligible
for
reregistration
and
have
additionally
identified
a
number
of
measures
that
the
Agency
believes
are
necessary
to
mitigate
risks
associated
with
the
remaining
uses
of
PCNB.
The
uses
of
PCNB
that
are
eligible
for
reregistration
are:
cole
crops
(
labeled
for
treatment
of
clubroot
only),
ornamental
bulbs
in
commercial
production,
and
seed
treatments.
The
Agency
is
now
publishing
its
reregistration
eligibility
and
risk
management
decisions
for
the
uses
of
PCNB,
along
with
the
technical
bases
for
these
decisions,
for
a
60­
day
public
comment
period.
The
enclosed
"
Reregistration
Eligibility
Decision
for
Pentachloronitrobenzene,"
which
was
approved
on
July
11,
2006,
contains
the
Agency's
decisions.

A
Notice
of
Availability
for
the
Reregistration
Eligibility
Decision
(
RED)
for
PCNB
has
been
published
in
the
Federal
Register.
To
obtain
a
copy
of
the
RED
document,
please
contact
the
OPP
Public
Regulatory
Docket
(
7502P),
1200
Pennsylvania
Ave,
NW,
Washington,
DC
20460,
Electronic
copies
of
the
RED
and
all
supporting
documents
also
are
available
at
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

This
document
and
the
process
used
to
develop
it
are
the
result
of
EPA's
program
to
facilitate
greater
public
involvement
and
participation
in
the
Agency's
pesticide
reregistration
and
tolerance
reassessment
decision
making.
Since
the
enactment
of
the
Food
Quality
Protection
Act
of
1996
(
FQPA),
EPA
has
undertaken
to
increase
transparency,
to
consult
with
stakeholders,
and
to
engage
the
public
in
developing
pesticide
reregistration
and
tolerance
reassessment
decisions.
The
revised
human
health
and
environmental
risk
assessments
for
PCNB
were
placed
in
the
public
docket
and
opened
for
public
comment
through
a
Federal
Register
notice
on
March
2,
2005.
Other
supporting
documentation
has
been
added
since
that
time,
and
is
likewise
available
to
the
public
via
the
docket.

To
mitigate
the
risks
associated
with
the
uses
of
PCNB
that
are
eligible
for
reregistration,
product
labels
must
be
revised
by
the
registrants
to
adopt
the
changes
set
forth
in
Section
V
of
this
document.
Instructions
for
registrants
on
submitting
revised
labeling
and
the
time
frame
for
doing
so
can
be
found
in
Section
V.

If
you
have
questions
on
this
document
or
the
proposed
label
changes,
please
contact
the
Special
Review
and
Reregistration
Division
representative,
Jill
Bloom,
at
(
703)
308­
8019.
For
questions
about
product
reregistration
and/
or
the
Product
data
call­
in
(
DCI)
that
accompanies
this
document,
please
contact
Bonnie
Adler
at
(
703)
308­
8523.

/
s/

Debra
Edwards,
Ph.
D.
Director,
Special
Review
and
Reregistration
Division
Attachment
Reregistration
Eligibility
Decision
for
Pentachloronitrobenzene
List
A
Case
0128
Approved
By:

______/
s/________________
Debra
Edwards,
Ph.
D.
Director,
Special
Review
and
Reregistration
Division
_____
July
11,
2006_____________
Date
TABLE
OF
CONTENTS
I.
Introduction
......................................................................................................................................................................
1
II.
Chemical
Overview.........................................................................................................................................................
2
A.
Regulatory
History
....................................................................................................................................................
2
B.
Chemical
Identification.............................................................................................................................................
3
C.
Use
Profile
...................................................................................................................................................................
4
D.
Estimated
Usage
of
Pesticide....................................................................................................................................
5
III.
Summary
of
PCNB
Risk
Assessments........................................................................................................................
5
A.
Human
Health
Risk
Assessment..............................................................................................................................
6
1.
Toxicity
of
PCNB...................................................................................................................................................
6
a)
Acute
Toxicity.....................................................................................................................................................
6
b)
Endpoint
Selection..............................................................................................................................................
7
c)
FQPA
Safety
Factor.........................................................................................................................................
8
d)
Population
Adjusted
Dose...............................................................................................................................
8
e)
Uncertainties
in
the
Toxicology
Database
to
be
Addressed
with
New
Data
Requirements..............................
9
2.
Dietary
Risk
Assessment.......................................................................................................................................
9
a)
Assumptions
and
Uncertainties......................................................................................................................
9
b)
Acute
Dietary
Risk.........................................................................................................................................
10
c)
Chronic
(
Noncancer)
Dietary
Risk...............................................................................................................
10
d)
Cancer
Dietary
Risk
......................................................................................................................................
11
e)
Dietary
Exposures
from
Drinking
Water....................................................................................................
11
3.
Residential
and
Other
Nonoccupational
Exposures
.......................................................................................
13
a)
Residential
Handlers......................................................................................................................................
13
b)
Residential
Post­
application
Risk
................................................................................................................
14
4.
Aggregate
Risk.....................................................................................................................................................
16
5.
Cumulative
Assessment
......................................................................................................................................
16
6.
Occupational
Risk
...............................................................................................................................................
17
a)
Toxicological
Endpoints
for
the
Occupational
Assessment
......................................................................
17
b)
Seed
Handler
Exposure
Information...........................................................................................................
17
c)
Soil
and
Foliar
Application
Exposure
Information....................................................................................
17
d)
Occupational
Handler
Risk
Summary........................................................................................................
18
e)
Occupational
Post­
application
Risks
...........................................................................................................
25
7.
Human
Incident
Data
.........................................................................................................................................
26
B.
Environmental
Risk
Assessment............................................................................................................................
27
1.
Fate
and
Transport
.............................................................................................................................................
27
a)
Metabolites......................................................................................................................................................
28
b)
Field
Dissipation.............................................................................................................................................
28
c)
Volatility
..........................................................................................................................................................
28
d)
Photodegradation...........................................................................................................................................
29
e)
Aerobic
and
Anaerobic
Metabolism............................................................................................................
29
f)
Mobility
............................................................................................................................................................
29
g)
Drift
and
Surface
Water................................................................................................................................
29
h)
Bioconcentration
............................................................................................................................................
29
2.
Impact
of
Fate
Characteristics
on
Risk
............................................................................................................
30
3.
Environmental
Loading......................................................................................................................................
31
4.
International
and
Domestic
Standards
for
Persistence,
Bioaccumlation,
and
Long­
range
Transport
...
31
a)
Persistence
.......................................................................................................................................................
32
b)
Bioaccumulation.............................................................................................................................................
32
c)
Long­
range
Transport
...................................................................................................................................
33
d)
Adverse
Effects
...............................................................................................................................................
33
e)
PBT
Criteria
and
the
Resource
Conservation
Challeng
...........................................................................
33
5.
Monitoring
Data
..................................................................................................................................................
34
6.
Estimated
Concentrations
of
PCNB
and
Metabolites
in
Water
Resources
.................................................
35
a)
Estimated
Environmental
Concentrations
(
EECs)
for
the
Ecological
Risk
Assessment
......................
35
b)
Drinking
Water
Concentrations
..................................................................................................................
38
7.
Estimates
of
Ecological
Risk...............................................................................................................................
38
a)
Risk
to
Birds....................................................................................................................................................
39
b)
Risk
to
Mammals
...........................................................................................................................................
43
c)
Risk
to
Fish
and
Aquatic
Invertebrates
......................................................................................................
46
d)
Risks
to
Insects
...............................................................................................................................................
49
e)
Risks
to
Terrestrial
and
Aquatic
Plants
......................................................................................................
49
8.
Risk
to
Endangered
Species
...............................................................................................................................
49
9.
Ecological
Incident
Reports................................................................................................................................
50
IV.
Risk
Management,
Reregistration,
and
Tolerance
Reassessment
Decision........................................................
50
A.
Determination
of
Reregistration
Eligibility..........................................................................................................
50
B.
Public
Comments
and
Responses...........................................................................................................................
51
C.
Regulatory
Position
.................................................................................................................................................
51
1.
Food
Quality
Protection
Act
Findings
..............................................................................................................
51
a)
"
Risk
Cup"
Determination
...........................................................................................................................
51
b)
Determination
of
Safety
to
U.
S.
Population................................................................................................
52
c)
Determination
of
Safety
to
Infants
and
Children.......................................................................................
52
d)
Endocrine
Disruptor
Effects
.........................................................................................................................
53
e)
Cumulative
Risks............................................................................................................................................
53
2.
Tolerance
Summary
............................................................................................................................................
54
a)
Tolerances
Currently
Listed
Under
40
CFR
§
180.291(
a).........................................................................
54
b)
Tolerances
Currently
Listed
Under
40
CFR
§
180.291(
b)
........................................................................
55
c)
Interim
Tolerances
Listed
Under
40
CFR
§
180.319..................................................................................
56
d)
Tolerances
That
Need
to
Be
Proposed
Under
40
CFR
§
180.291(
a)
........................................................
56
e)
Codex
Harmonization
....................................................................................................................................
57
f)
Analytical
Methods
and
Residue
Data
Requirements
...............................................................................
57
3.
Regulatory
Rationale
..........................................................................................................................................
58
a)
Chronology
of
Assessments
and
Mitigation
Proposals..............................................................................
58
b)
Summary
of
Mitigation
Measures
Proposed
by
Registrants
...................................................................
60
c)
Human
Health
Risk
Mitigation....................................................................................................................
61
d)
Ecological
Risk
Mitigation............................................................................................................................
65
e)
Synthesis
of
Risk
Ranking
from
RQs
and
Environmental
Loading........................................................
69
f)
Benefits
of
PCNB
Use
.....................................................................................................................................
73
4.
Determination
of
Eligibility
for
Reregistration................................................................................................
76
5.
Labeling
Requirements.......................................................................................................................................
79
6.
Endangered
Species
Considerations
.................................................................................................................
79
7.
Spray
Drift
Management
...................................................................................................................................
80
V.
What
Registrants
Need
to
Do......................................................................................................................................
80
A.
Submissions
for
Technical­
Grade
Active
Ingredient
Products
.........................................................................
80
1.
Within
90
Days
of
Receipt
of
the
Generic
DCI
................................................................................................
80
2.
Within
Generic
DCI
Deadlines
..........................................................................................................................
80
B.
Submissions
for
End­
Use
Products
Containing
PCNB.......................................................................................
81
1.
Within
90
Days.....................................................................................................................................................
81
2.
Within
Product
DCI
Deadlines..........................................................................................................................
81
C.
Manufacturing­
Use
Products 
Data
Requirements
and
Labeling
..................................................................
82
1.
Generic
Data
Requirements
...............................................................................................................................
82
2.
Labeling
for
Manufacturing­
Use
Products
......................................................................................................
84
D.
End­
Use
Products 
Data
Requirements
and
Labeling......................................................................................
84
1.
Product­
Specific
Data
Requirements................................................................................................................
84
2.
Labeling
for
End­
Use
Products..........................................................................................................................
84
E.
Existing
Stocks..........................................................................................................................................................
85
F.
Required
Labeling
Changes
...................................................................................................................................
85
­
i
­
­
Glossary
of
Terms
and
Abbreviations
AGDCI
Agricultural
Data
Call­
In
ai
Active
Ingredient
aPAD
Acute
Population
Adjusted
Dose
AR
Anticipated
Residue
BCF
Bioconcentration
Factor
CFR
Code
of
Federal
Regulations
cPAD
Chronic
Population
Adjusted
Dose
CSF
Confidential
Statement
of
Formula
CSFII
USDA
Continuing
Surveys
for
Food
Intake
by
Individuals
DCI
Data
Call­
In
DEEM
Dietary
Exposure
Evaluation
Model
DFR
Dislodgeable
Foliar
Residue
DWLOC
Drinking
Water
Level
of
Comparison.
EC
Emulsifiable
Concentrate
Formulation
EEC
Estimated
Environmental
Concentration.
EP
End­
Use
Product
EPA
Environmental
Protection
Agency
ESA
Endangered
Species
Act
FDA
Food
and
Drug
Administration
FIFRA
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
FFDCA
Federal
Food,
Drug,
and
Cosmetic
Act
FQPA
Food
Quality
Protection
Act
FOB
Functional
Observation
Battery
G
Granular
Formulation
GENEEC
Tier
I
Surface
Water
Computer
Model
GLN
Guideline
Number
HAFT
Highest
Average
Field
Trial
IR
Index
Reservoir
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/
l,
mg/
kg
or
ppm.
LD50
Median
Lethal
Dose.
A
statistically
derived
single
dose
that
can
be
expected
to
cause
death
in
50%
of
the
test
animals
when
administered
by
the
route
indicated
(
oral,
dermal,
inhalation).
It
is
expressed
as
a
weight
of
substance
per
unit
weight
of
animal,
e.
g.,
mg/
kg.
LOC
Level
of
Concern
LOD
Limit
of
Detection
LOAEL
Lowest
Observed
Adverse
Effect
Level
MATC
Maximum
Acceptable
Toxicant
Concentration
µ
g/
g
Micrograms
Per
Gram
µ
g/
L
Micrograms
Per
Liter
mg/
kg/
day
Milligram
Per
Kilogram
Per
Day
mg/
L
Milligrams
Per
Liter
MOE
Margin
of
Exposure
MUP
Manufacturing­
Use
Product
MRID
Master
Record
Identification
(
number).
EPA's
system
of
recording
and
tracking
studies
submitted.
NA
Not
Applicable
NAWQA
USGS
National
Water
Quality
Assessment
NPDES
National
Pollutant
Discharge
Elimination
System
NR
Not
Required
NOAEL
No
Observed
Adverse
Effect
Level
OP
Organophosphate
­
ii
­
­
OPP
EPA
Office
of
Pesticide
Programs
OPPTS
EPA
Office
of
Prevention,
Pesticides
and
Toxic
Substances
PCA
Percent
Crop
Area
PAD
Population
Adjusted
Dose
PDP
USDA
Pesticide
Data
Program
PHED
Pesticide
Handler's
Exposure
Data
PHI
Preharvest
Interval
ppb
Parts
Per
Billion
PPE
Personal
Protective
Equipment
ppm
Parts
Per
Million
PRZM/
EXAMS
Tier
II
Surface
Water
Computer
Model
Q1*
The
Carcinogenic
Potential
of
a
Compound,
Quantified
by
the
EPA's
Cancer
Risk
Model
RAC
Raw
Agriculture
Commodity
RED
Reregistration
Eligibility
Decision
REI
Restricted
Entry
Interval
RfD
Reference
Dose
RQ
Risk
Quotient
SCI­
GROW
Tier
I
Ground
Water
Computer
Model
SAP
Science
Advisory
Panel
SF
Safety
Factor
SLC
Single
Layer
Clothing
SLN
Special
Local
Need
(
Registrations
Under
Section
24(
c)
of
FIFRA)
TGAI
Technical
Grade
Active
Ingredient
TRR
Total
Radioactive
Residue
USDA
United
States
Department
of
Agriculture
USGS
United
States
Geological
Survey
UF
Uncertainty
Factor
UV
Ultraviolet
WPS
Worker
Protection
Standard
­
iii
­
­
Pentachlorobenzene
Reregistration
Eligibility
Decision
Team
USEPA/
Office
of
Pesticide
Programs:

Biological
and
Economic
Analysis
Division
Tara
Chand­
Goyal,
Leonard
Yourman
Herbicide
and
Insecticide
Branch
David
Donaldson
Economic
Analysis
Branch
Environmental
Fate
and
Effects
Division
Tom
Steeger,
Cheryl
Sutton,
Environmental
Risk
Branch
IV
R.
David
Jones
John
Ravenscroft
formerly
of
Environmental
Risk
Branch
IV
Health
Effects
Division
Diana
Locke,
Sherrie
Kinard,
formerly
of
Reregistration
Branch
2
Mohsen
Sahafayen
Seyed
Tadayon
Reregistration
Branch
3
Larry
Chitlik,
Alberto
Protzel
Toxicology
Branch
Registration
Division
Mary
Waller
Fungicide
Branch
Special
Review
and
Reregistration
Division
Bonnie
Adler,
Mark
Perry
Product
Reregistration
Branch
Jill
Bloom,
Tom
Myers,
Margaret
Rice
Reregistration
Branch
2
USEPA/
Office
of
General
Counsel:

Angela
Huskey
US
Department
of
Agriculture:

Kent
Smith
­
iv
­
­
Executive
Summary
This
document
presents
EPA's
decision
on
the
tolerance
reassessment
and
reregistration
eligibility
of
the
registered
uses
of
pentachloronitrobenzene
(
PCNB).
In
making
its
decisions,
the
Agency
considered
data
previously
required
of
and
submitted
by
the
registrants,
current
guidelines
for
conducting
acceptable
studies
to
generate
such
data,
published
scientific
literature,
and
public
comments
on
the
human
health
and
environmental
risk
assessments.
The
Agency
has
reassessed
the
fourteen
tolerances
established
for
PCNB.
The
Agency
has
determined
that
the
currently
registered
uses
of
PCNB
for
cole
crops
(
for
control
of
clubroot
only),
commercial
production
of
flowering
bulbs,
and
seed
treatment
are
eligible
for
reregistration,
provided
changes
are
made
to
product
labels
as
specified
in
this
document.
Data
requirements
associated
with
these
uses
are
detailed
in
the
RED.
The
remaining
uses
of
PCNB
are
ineligible
for
reregistration.

PCNB
is
an
organochlorine
fungicide
used
to
control
diseases
on
vegetables
(
predominantly
green
beans
and
cole
crops),
field
crops
(
cotton,
potatoes,
and
peanuts),
turf,
ornamentals,
and
seeds
(
seed
treatments
of
barley,
beans,
corn,
cotton,
oats,
peas,
peanut,
potato,
rice,
safflower,
sorghum,
soybean,
sugar
beet,
and
wheat).
The
Agency
estimates
total
usage
of
PCNB
at
770,000
to
1,000,000
lbs/
year,
with
the
greatest
agricultural
use
on
cotton
(
400,000
lbs/
year)
and
potatoes
(
60,000
lbs/
year);
turf
applications
are
estimated
at
250,000­
500,000
lbs/
year
(
90­
95%
of
which
is
used
on
golf
courses).

The
Agency
assessed
the
human
health
and
environmental
risks
of
PCNB
as
currently
registered.
The
Agency
also
assessed
the
benefits
associated
with
the
currently
registered
uses
of
PCNB.
The
reregistration
eligibility
decision
for
PCNB
is
based
on
these
assessments.
The
risk
assessments
went
through
several
iterations
based
on
public
comments,
proposed
mitigation,
and
the
correction
of
an
error
in
and
refinements
to
the
dietary
assessment.
A
chronology
of
the
Agency
risk
reassessments
and
registrant
responses
may
be
helpful
in
tracking
the
risk
conclusions
discussed
in
this
document.

Chronology
The
Agency
released
risk
assessments
revised
to
address
public
comments
(
mostly
technical
in
nature)
on
March
2,
2005,
and
determined
at
that
time
that
the
dietary,
residential,
aggregate,
ecological,
and
some
occupational
risks
associated
with
the
uses
of
PCNB
were
of
concern.
The
risks
discussed
in
Section
III
of
the
RED
reflect
the
assessments
made
public
in
March
2005.

On
June
10,
2005,
the
two
registrants
of
technical
grade
PCNB,
Amvac
and
Chemtura,
proposed
a
risk
mitigation
plan
focused
mainly
on
reducing
dietary
and
worker
risk.
Measures
proposed
by
the
registrants
included:

°
reduction
of
maximum
seasonal
application
rates
on
several
use
sites
°
restriction
of
golf
course
use
to
tees,
greens,
and
fairways
°
terminations
of
the
use
on
garlic
°
prohibition
of
some
application
methods
and
formulation
types
­
v
­
­
°
additional
PPE
for
workers
The
Agency
determined
that
the
registrant
proposal,
if
implemented,
would
adequately
address
most
of
the
occupational
risks,
but
that
dietary,
residential,
and
ecological
risks
would
still
be
of
concern.

After
the
Agency
evaluated
the
proposal,
Amvac
and
Chemtura
informally
supplemented
their
original
mitigation
plan
by
proposing
that
all
turf
uses
of
PCNB
except
golf
course
tees,
greens,
and
fairways
be
terminated.
The
Agency
initiated
a
review
of
this
addition
to
the
proposal.
At
the
same
time,
the
Agency
corrected
an
error
in
its
dietary
risk
assessment
related
to
how
PCNB
residues
partition
in
the
liquid
and
fat
portions
of
milk,
refined
the
theoretical
composition
of
the
diet
for
lactating
cows
to
more
realistically
reflect
its
contribution
to
residues
in
milk,
and
incorporated
a
new
adsorption
coefficient
to
better
represent
estimated
water
concentrations
associated
with
the
turf
use.
The
risks
discussed
in
Section
IV
of
the
RED
reflect
these
changes
and
the
Agency's
assessment
of
the
registrants'
complete
risk
mitigation
proposal.

The
Agency
concluded
that
the
registrants'
complete
proposal,
together
with
the
correction
and
refinement
of
the
dietary
assessment,
would
decrease
estimates
of
dietary
risk
below
levels
of
concern,
and
eliminate
occupational
risks
from
PCNB
use
on
turf
sites
the
registrants
proposed
for
termination.
The
dietary
risk
conclusions
are
captured
in
an
October
20,
2005
assessment.
The
residential
and
aggregate
risks
would
also
be
reduced
by
the
proposal,
although
the
residential
risk
posed
by
the
use
of
PCNB
on
ornamentals
in
residential
settings
would
continue
to
be
of
concern.

Although
the
registrants'
proposal
would
also
reduce
wildlife
exposures
to
PCNB,
the
Agency
did
not
find
it
adequate
to
address
ecological
risk
concerns.
The
ecological
risk
quotients
associated
with
the
registrants'
proposal
are
captured
in
documents
dated
July
7
and
August
9,
2005.
Of
particular
concern
are
the
widespread
use
of
PCNB
and
the
contribution
of
the
environmental
fate
and
transport
characteristics
of
PCNB
and
its
metabolites
to
ecological
risk.
These
characteristics,
particularly
persistence,
bioaccumulative
potential
and
the
potential
for
long­
range
atmospheric
transport,
are
discussed
in
a
synopsis
dated
April
26,
2006;
the
synopsis
also
captures
the
Agency's
conclusions
about
their
impact
on
environmental
risk.
The
environmental
risks
associated
with
the
registrants'
complete
mitigation
are
discussed
in
Section
IV
of
the
RED.

The
risks
summarized
in
this
document
are
those
that
result
only
from
the
use
of
PCNB.
The
Food
Quality
Protection
Act
(
FQPA)
requires
that
the
Agency
consider
"
available
information"
concerning
the
cumulative
effects
of
a
particular
pesticide's
residues
and
"
other
substances
that
have
a
common
mechanism
of
toxicity."
The
reason
for
consideration
of
other
substances
is
to
account
for
the
possibility
that
low­
level
exposures
to
multiple
chemical
substances
that
cause
a
common
toxic
effect
by
a
common
toxic
mechanism
could
lead
to
the
same
adverse
health
effect
as
a
higher
level
of
exposure
to
any
of
the
substances
individually.
Unlike
other
pesticides
for
which
EPA
has
followed
a
cumulative
risk
approach
based
on
a
common
mechanism
of
toxicity,
EPA
has
not
made
a
common
mechanism
of
toxicity
finding
for
PCNB.
Chlorothalonil
and
pentachlorophenol,
two
pesticides
in
the
same
general
family
as
­
vi
­
­
PCNB,
do
not
appear
to
result
in
the
same
health
endpoints.
The
endpoints
used
to
assess
human
health
risks
for
PCNB
are
primarily
thyroid
hypertrophy
and
hepatocellular
hypertrophy
and
hyperplasia.
The
endpoints
for
chlorothalonil
have
been
identified
as
various
kidney
and
forestomach
effects,
and
the
endpoints
identified
for
pentachlorophenol
are
carcinogenicity
and
developmental
effects.
The
Agency
has
not
undertaken
a
comprehensive
assessment
of
organochlorine
pesticides
with
respect
to
common
mechanism.
For
information
regarding
EPA's
efforts
to
determine
which
chemicals
have
a
common
mechanism
of
toxicity
and
to
evaluate
the
cumulative
effects
of
such
chemicals,
see
the
policy
statements
released
by
EPA's
Office
of
Pesticide
Programs
concerning
common
mechanism
determinations
and
procedures
for
cumulating
effects
from
substances
found
to
have
a
common
mechanism
on
EPA's
website
at
http://
www.
epa.
gov/
pesticides/
cumulative/.

Environmental
Fate
and
Ecological
Risk
The
fate
characteristics
of
PCNB
and
its
metabolites,
their
ecotoxicity
and
estimated
concentrations
in
the
environment,
and
the
ecological
risks
posed
by
the
currently
labeled
uses
of
PCNB
are
detailed
in
Section
III
of
the
RED.
The
persistence,
bioaccumulative
potential,
and
potential
for
long­
range
transport
of
PCNB
and
its
metabolites
are
key
to
understanding
the
extent
and
scope
of
ecological
exposures
associated
with
the
use
of
PCNB.

Persistence
Over
80
metabolites
have
been
identified
for
PCNB.
The
predominant
metabolites
of
PCNB
in
the
environment
are
PCA,
PCTA,
and
pentachlorobenzene.
PCNB
and
its
metabolites
are
very
persistent
in
the
environment.
PCNB
alone
has
a
measured
aerobic
soil
metabolism
halflife
of
over
six
months;
PCNB
and
its
metabolites
combined
have
an
aerobic
soil
metabolism
halflife
of
close
to
three
years.
Field
data
show
that
PCNB
residues
can
be
found
in
rotational
crops
several
years
after
the
last
application
of
PCNB.
The
persistence
of
PCNB
limits
the
effects
of
depuration
(
an
organism's
ability
to
remove
accumulated
toxins
from
its
system)
and
increases
opportunities
for
exposure.
PCNB
and
its
metabolites
have
persistence
properties
that
exceed
national
and
international
thresholds
for
identifying
persistent
chemicals.

Bioaccumulation
The
fate
characteristics
of
PCNB
and
its
metabolites
indicate
that
they
have
the
potential
to
bioaccumulate,
or
increase
in
concentration
the
food
chain.
Bioconcentration
data
for
PCNB
are
limited,
with
Bioconcentration
Factors
up
to
1100
in
whole
fish
and
3100
in
algae.
Modeling
suggests
that
the
aquatic
food
chain
is
a
likely
mechanism
for
bioaccumulation
of
PCNB.
PCNB
exceeds
national
thresholds
for
identifying
chemicals
with
bioaccumulative
potential.
The
extent
to
which
PCNB
and
its
metabolites
may
bioaccumulate
in
humans
(
at
the
top
of
the
food
chain)
is
a
source
of
uncertainty
and
concern
in
the
consideration
of
human
health
risks
also,
and
the
Agency
is
requiring
data
to
help
resolve
this
uncertainty.

Long­
range
Transport
­
vii
­
­
PCNB
is
a
moderately
volatile
compound.
Both
PCNB
and
PCA
show
a
potential
for
long­
range
atmospheric
transport.
Field
data
demonstrate
that
significant
quantities
of
PCNB
can
volatilize
from
the
field
and
will
undergo
long­
range
atmospheric
transport.
Monitoring
data
are
limited,
but
PCNB
has
been
detected
at
sites
in
Canada
distant
from
areas
where
it
could
have
been
applied.
EPA's
environmental
exposure
models
do
not
account
for
long­
range
transport
and
so
may
underestimate
risks.

Environmental
Loading
The
combined
effect
of
these
fate
characteristics
on
the
amount
of
the
pesticide
and
its
metabolites
entering
and
remaining
in
the
environment
is
referred
to
in
this
document
as
"
environmental
loading."
Environmental
loading
varies
with
the
different
use
sites
for
a
pesticide,
and
is
a
function
of
how
much
of
the
pesticide
is
introduced
into
the
environment,
as
measured
by
usage
(
pounds
applied
on
an
annual
basis),
percent
crop
treated
(
the
proportion
of
a
given
use
site
that
is
treated
in
a
year),
application
rates,
and
application
methods
(
for
a
volatile
pesticide
like
PCNB,
a
foliar
application
may
result
in
more
volatilization
and
a
greater
potential
for
long­
range
transport).

The
Impact
of
Fate
Characteristics
on
Ecological
Risk
The
Agency
believes
that
the
persistence,
bioaccumulative
potential,
potential
for
longrange
transport
and
other
fate
characteristics
of
PCNB
and
its
metabolites
contribute
to
ecological
risk
in
ways
that
cannot
be
accounted
for
by
modeling
risk
quotients,
that
ecological
risk
quotients
derived
from
these
models
are
likely
to
underestimate
the
magnitude
of
risk,
and
that
the
environmental
fate
characteristics
of
PCNB
result
in
increased
numbers
and
wider
distribution
of
organisms
at
risk.
The
Agency
has
conducted
a
qualitative
analysis
of
the
effect
of
these
characteristics
on
risk.

Wildlife
Exposures
The
Agency
utilized
the
Tier
II
screening
Pesticide
Root
Zone
Model
and
the
Exposure
Analysis
Model
System
(
PRZM/
EXAMS)
to
estimate
surface
water
exposures
for
aquatic
wildlife
from
PCNB
and
its
metabolites.

Water
concentrations
were
originally
assessed
for
currently
labeled
uses
of
PCNB,
and
then
again
after
the
registrants
proposed
their
risk
mitigation
plan.
Under
the
original
assessment,
the
scenario
that
resulted
in
the
greatest
estimated
environmental
exposures
(
EECs)
in
surface
water
was
a
turf
scenario
modeled
using
Pennsylvania
soil
and
weather
conditions.
EECs
from
the
original
assessment
are
found
in
Section
III,
Table
17;
EECs
modeled
on
the
registrants'
mitigation
proposal
are
found
in
Section
IV,
Table
38.

The
Agency
used
several
different
methods
to
estimate
exposures
to
terrestrial
wildlife.
Models
were
used
to
estimate
exposures
from
ingestion
of
treated
seed
and
from
ingestion
of
a
variety
of
food
items
contaminated
via
spray
and
chemigation
applications
of
PCNB.
In
the
original
assessment,
estimated
concentrations
on
terrestrial
forage
items
were
based
on
the
ELL
­
viii
­
­
FATE
model;
a
more
recent
version
of
that
model,
the
TREX
model,
subsequently
was
used
to
assess
estimated
concentrations
based
on
the
registrants'
mitigation
proposal.
The
Agency
views
TREX
to
be
a
more
refined
terrestrial
exposure
model
than
ELL­
FATE.
The
registrants'
mitigation
proposal
would
not
reduce
seed
treatment
application
rates,
so
the
Agency
did
not
reassess
exposures
to
treated
seed.
EECs
for
terrestrial
food
items
from
the
original
assessment
are
found
in
Section
III;
terrestrial
EECs
modeled
based
on
the
registrants'
mitigation
proposal
are
found
in
several
support
documents
("
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,"
February
15,
2005;
"
Revised
Tier
II
Surface
Water
Exposure
Values
and
Terrestrial
Exposure
Values
for
PCNB
Based
on
Proposed
Lower
Application
Rates
(
Risk
Mitigation
Phase),"
August
9,
2005)
and
are
summarized
in
Section
IV.
The
support
documents
can
be
accessed
via
http://
www.
regulations.
gov/,
Docket
Number
OPP­
2004­
0202).

Toxicity
to
Non­
target
Organisms
PCNB
is
highly
toxic
to
freshwater
fish
and
invertebrates
and
is
very
highly
toxic
to
estuarine/
marine
fish
and
invertebrates
on
an
acute
exposure
basis.
The
Agency
uses
measures
of
toxicity
in
freshwater
fish
as
surrogates
for
toxicity
to
aquatic­
phase
amphibians.
Chronic
effects
in
freshwater
fish
and
invertebrates
include
reduced
number
of
eggs
produced
and
reductions
in
the
number
of
young
which
survive.
No
chronic
toxicity
data
are
available
for
estuarine/
marine
animals.
Since
estuarine/
marine
invertebrates
appear
to
be
much
more
sensitive
to
PCNB
than
their
freshwater
counterparts
on
an
acute
exposure
basis,
it
is
reasonable
to
assume
that
they
also
may
be
more
sensitive
on
a
chronic
basis.

PCNB
is
practically
non­
toxic
to
birds
and
mammals
on
an
acute
basis.
For
birds,
chronic
effects
include
reproductive
and
growth
effects.
The
Agency
uses
measures
of
toxicity
in
birds
as
surrogates
for
toxicity
to
reptiles
and
terrestrial­
phase
amphibians.
For
mammals,
laboratory
studies
conducted
in
rodents
to
facilitate
the
assessment
of
chronic
health
effects
for
humans
provide
the
data
that
were
used
to
assess
risks
to
terrestrial
mammals,
but
the
relevance
of
the
endpoints
from
the
selected
study
(
liver
and
thyroid
effects
in
a
2­
generation
reproduction
study
in
rats)
to
wildlife
is
not
clear.
An
alternate
and
more
sensitive
endpoint
for
chronic
mammalian
exposures
(
reduced
pup
weight,
from
a
different
2­
generation
rat
reproduction
study
submitted
to
the
Agency)
may
be
more
relevant
to
wildlife
than
the
endpoint
selected
for
the
ecological
risk
assessment.
The
alternate
endpoint
was
identified
by
the
Agency
after
the
ecological
effects
assessment
was
completed
and
so
is
not
a
part
of
the
posted
risk
assessments.
Estimates
of
mammalian
risk
based
on
this
alternate
endpoint
would
be
much
greater
than
those
cited
in
the
assessment.

PCNB
is
practically
nontoxic
to
bees
on
an
acute
exposure
basis.
Few
data
are
available
for
aquatic
or
terrestrial
plants,
although
growers
have
reported
phytoxicity
to
some
grass
species
and
varieties,
and
there
is
one
reported
adverse
effect
incident
in
which
PCNB
was
implicated
in
poor
germination
of
cottonseed.

Risk
Quotients
­
ix
­
­
Risks
to
wildlife
typically
are
estimated
by
the
Agency
as
the
ratio
of
estimated
exposures
of
the
subject
pesticide
in
water
(
for
aquatic
life)
and
food
(
for
terrestrial
life)
to
toxicity
as
measured
by
adverse
effects
endpoints.
The
Agency
compares
these
risk
quotients
(
RQs)
to
levels
of
concern
(
LOCs)
for
the
relevant
categories
of
terrestrial
and
aquatic
organisms
and
time
frames
of
exposure.
The
Agency
has
calculated
RQs
for
acute
and
chronic
exposures
of
birds
and
mammals
of
several
sizes
(
for
a
number
of
food
sources),
and
freshwater
fish
and
invertebrates.
No
chronic
toxicity
data
are
available
for
estuarine/
marine
fish
or
invertebrates,
so
the
Agency
cannot
calculate
chronic
RQs
for
these
taxa.
Since
estuarine/
marine
invertebrates
appear
to
be
much
more
sensitive
to
PCNB
than
their
freshwater
counterparts
on
an
acute
exposure
basis,
it
is
reasonable
to
assume
that
they
would
be
more
sensitive
on
a
chronic
basis,
with
higher
RQs.
Risk
Quotients
associated
with
the
currently
registered
uses
of
PCNB
exceed
levels
of
concern
for
most
species
type­
use
site
combinations
that
have
been
assessed.

Based
on
the
registrants'
mitigation
proposal,
RQs
would
still
exceed
LOCs
for
birds,
reptiles,
terrestrial­
phase
amphibians,
and
mammals
for
chronic
risks
and
chronic
risk
to
endangered
species
in
association
with
several
use
sites,
and
also
for
acute,
acute
endangered
species,
and
chronic
risks
and
chronic
risk
to
endangered
species
for
fish,
invertebrates,
and
aquatic­
phase
amphibians.
Although
some
of
the
RQs
would
be
reduced,
risks
of
concern
would
persist,
particularly
based
on
consideration
of
the
persistence,
bioaccumulation,
and
long­
range
transport
potential
of
PCNB
and
its
metabolites,
and
the
potential
for
wildlife
exposures
from
unincorporated
applications
of
PCNB
on
sites
such
as
turf
and
potatoes.

A
detailed
discussion
of
the
Risk
Quotients
associated
with
currently
labeled
PCNB
uses
is
found
in
Section
III
of
the
RED;
discussion
of
the
RQs
that
would
be
associated
with
the
registrants'
mitigation
proposal
may
be
found
in
Section
IV.

Endangered
Species
Endangered
species
LOCs
associated
with
the
use
of
PCNB
are
exceeded
for
aquatic
and
terrestrial
species.

To
address
concerns
about
risks
to
Federally­
listed
endangered
and
threatened
species
from
pesticide
use,
the
Agency
has
developed
the
Endangered
Species
Protection
Program.
Through
this
program,
EPA
will
use
toxicity
and
exposure
data
developed
for
Reregistration
Eligibility
Decisions
and
consider
ecological
parameters,
use
information,
geographic
relationships
between
specific
pesticide
uses,
as
well
as
biological
requirements
and
behavioral
aspects
of
a
particular
species
for
a
species­
specific
analysis
of
PCNB
use.
The
Agency's
species­
specific
analysis
will
take
into
consideration
any
risk
mitigation
measures
implemented
as
part
of
the
RED
decision
for
PCNB.
Following
this
future
species­
specific
analysis,
a
determination
whether
there
is
a
likelihood
of
potential
effects
to
a
listed
species
may
result
in
additional
limitations
on
the
use
of
PCNB,
other
measures
to
mitigate
any
potential
effects,
or
consultations
with
the
Fish
and
Wildlife
Service
and/
or
the
National
Marine
Fisheries
as
appropriate.
Until
a
species­
specific
analysis
is
completed,
the
ecological
risk
mitigation
measures
being
implemented
through
the
RED
will
reduce
the
likelihood
that
endangered
and
threatened
species
may
be
exposed
to
PCNB.
Information
about
the
Agency's
assessment
process
for
threatened
and
endangered
species
is
­
x
­
­
posted
at
www.
epa.
gov/
espp.
Once
an
Endangered
Species
assessment
is
completed,
further
changes
to
the
PCNB
registrations
may
be
necessary
as
explained
in
Section
III
B.
8
of
the
RED.

Human
Health
Risks
Dietary
Risk
The
PCNB
dietary
risk
assessment
quantifies
chronic
risks
only.
An
acute
health
risk
endpoint
has
not
been
identified
for
PCNB,
so
an
acute
dietary
risk
assessment
has
not
been
conducted.
The
method
for
predicting
chronic
dietary
risk
associated
with
PCNB
is
also
appropriate
for
assessing
the
cancer
risk,
so
no
separate
assessment
of
carcinogenic
risk
is
necessary.
The
chronic
dietary
(
food
only)
risk
assessment
is
considered
to
be
a
highly
refined
assessment
utilizing
all
available
monitoring
data,
percent­
crop­
treated
information,
and
processing
factors
from
residues
in
food
based
on
field
trials.
The
screening
models
PRZM/
EXAMS
and
SCI­
GROW
were
used
to
estimate
the
drinking
water
concentrations
of
PCNB
and
PCA
in
surface
water
and
groundwater.

Dietary
risk
was
originally
assessed
for
currently
labeled
uses
of
PCNB,
and
then
again
after
the
registrants
proposed
their
risk
mitigation
plan.
The
registrants'
proposal
to
eliminate
the
broadcast
application
of
PCNB
to
bulbs
would
greatly
reduce
estimates
of
concentrations
in
groundwater,
and
the
proposal
to
terminate
all
turf
applications
of
PCNB
except
to
tees,
greens,
and
fairways
allowed
the
Agency
to
reassess
surface
water
concentrations
based
on
a
Golf
Course
Adjustment
Factor
(
GCAF)
of
34%,
to
account
for
that
portion
of
golf
course
turf
on
which
PCNB
could
be
used.
As
a
result
of
this
proposal,
estimates
of
surface
water
concentrations
would
be
reduced
relative
to
those
in
the
original
assessment.
The
highest
modeled
surface
water
drinking
water
concentration
from
the
original
assessment
was
65.5
µ
g/
L
for
turf,
and
the
highest
estimate
from
the
assessment
based
on
the
risk
mitigation
proposal
would
be
10.3
µ
g/
L,
for
cabbage.
Food­
only
dietary
exposures
are
based
on
field
trials
and
currently
labeled
use
rates,
and
the
impact
of
proposed
reductions
in
application
rates
on
residues
in
food
cannot
be
estimated.

The
chronic
dietary
risks
for
food
plus
water
were
initially
assessed
at
greater
than
100%
of
the
chronic
Population
Adjusted
Dose
(
cPAD)
for
several
population
subgroups
(
children
less
than
one
year,
173%;
children
one
to
two
years,
214%;
children
three
to
five
years,
154%),
and
were
of
concern.
Mitigation
measures
proposed
by
the
registrants,
and
the
correction
and
refinement
of
the
dietary
assessment
relating
to
the
contribution
of
milk
to
dietary
risk
were
incorporated
into
the
subsequent
dietary
assessment,
yield
dietary
risk
estimates
below
levels
of
concern
for
the
general
population
and
all
subgroups.
A
more
detailed
discussion
of
the
original
dietary
risk
assessment
is
found
in
Section
III
of
the
RED,
and
discussion
of
the
dietary
risks
that
would
be
associated
with
the
registrants'
mitigation
proposal
and
the
correction
and
refinement
of
the
dietary
assessment
may
be
found
in
Section
IV.

Inadvertent
Residues
For
a
number
of
use
sites
not
registered
for
PCNB
use,
associated
commodities
show
detectable
levels
of
PCNB
residues.
The
Agency
believes
that
the
persistence
of
PCNB
in
soil
­
xi
­
­
results
in
uptake
of
residues
by
growing
plants
for
several
years
after
PCNB
is
applied.
The
dietary
risk
assessment
was
conducted
both
for
residues
from
registered
crops
only,
and
for
residues
from
registered
crops
plus
residues
from
crops
for
which
PCNB
is
not
registered.
Carrots,
spinach,
cucumber,
and
ginseng,
for
which
PCNB
is
not
registered,
contribute
to
the
latter
of
these.
Other
food
sources
(
fresh
winter
squash,
asparagus,
pears,
celery,
aquacultureraised
tilapia,
and
ginger
root)
also
appear
to
contribute
to
dietary
residues,
but
data
are
insufficient
to
support
their
use
in
quantifying
risk.
The
Agency
anticipates
that
implementation
of
risk
mitigation
measures
for
PCNB
and
the
consequent
reduction
in
overall
usage,
will
result
in
fewer
commodities
with
inadvertent
residues
of
the
pesticide
and
its
metabolites.

Tolerances
The
fourteen
tolerances
established
for
residues
of
PCNB
have
been
reassessed,
and
found
to
satisfy
the
requirements
for
a
safety
finding
under
FIFRA
and
FQPA,
based
on
implementation
of
the
requirements
of
this
RED.
The
tolerances
could
change
at
a
later
time
based
on
the
new
analytical
method
required
by
the
RED,
residue
data
currently
in
review,
or
product
cancellations
resulting
from
implementation
of
the
terms
of
the
RED.

Non­
occupational
Risk
PCNB
products
are
marketed
for
homeowner
use
on
residential
lawns
and
ornamental
plants.
PCNB
products
are
also
marketed
for
use
by
professional
applicators
on
residential
turf,
golf
courses,
and
commercial/
industrial
and
recreational
turf,
as
well
as
non­
turf
ornamentals.
Residential
handlers
may
be
exposed
to
PCNB
during
applications
to
home
lawns
and
ornamental
plants.
Adults
and
children
alike
may
be
exposed
after
these
applications;
other
post­
application
exposures
may
take
place
at
golf
courses,
parks,
and
schools.
Post­
application
non­
occupational
exposures
from
treatment
of
commercial/
industrial
and
recreational
turf,
and
turf
at
parks
and
schools,
are
not
assessed
individually,
but
are
expected
to
be
similar
to
residential
exposure
from
lawns
after
application
of
PCNB.
Residential
post­
application
exposures
to
treated
ornamentals
could
not
be
assessed
because
the
Agency
lacks
a
methodology
for
estimating
such
exposures.

The
residential
handler
exposures
to
PCNB
are
considered
to
be
short­
term
in
nature
due
to
the
episodic
use
associated
with
homeowner
products.
For
PCNB,
residential
handler
margins
of
exposure
(
MOEs)
of
less
than
1000
represent
risks
of
concern.
MOEs
were
estimated
for
both
dermal
and
inhalation
exposures.
Based
on
the
currently
labeled
uses
of
PCNB,
some
residential
handler
scenarios
pose
risks
of
concern,
with
MOEs
ranging
from
12
to
490
for
certain
application
methods.

After
application
to
turf
and
ornamentals,
short­
to
intermediate­
term
dermal
exposures
are
anticipated
for
adults
and
children
in
residential
settings,
and
in
parks
and
other
public
areas.
Incidental
oral
exposure
is
also
expected
to
occur
for
small
children,
and
is
combined
with
their
dermal
exposures
where
applicable
(
i.
e.,
playing
on
turf).
Exposure
is
also
expected
in
golfers
playing
on
courses
treated
with
PCNB.
Post­
application
MOEs
of
less
than
1000
represent
risks
of
concern.
Based
on
the
Agency's
initial
assessment,
practically
all
residential
turf
postapplication
and
golfer
scenarios
pose
risks
of
concern.
Of
these
scenarios,
MOEs
for
post
­
xii
­
­
application
exposures
on
lawns
are
as
low
as
<
10
(
for
hand­
to­
mouth
and
object­
to­
mouth
exposures
of
children).
Golfer
MOEs
were
not
estimated
to
increase
above
1000
until
nine
days
after
application.

The
registrants'
proposal
to
terminate
residential
turf
use
would
eliminate
the
risks
associated
with
residential
turf.
Risks
associated
with
the
use
of
PCNB
on
residential
ornamentals
would
be
unaffected
by
the
proposal,
and
the
Agency
remains
concerned
about
them.
The
registrants'
mitigation
proposal
would
not
affect
exposures
for
golfers
after
application
of
PCNB
to
golf
course
turf,
but
recently
submitted
data
from
the
ARTF
have
been
reviewed
in
the
context
of
golfer
reentry,
and
the
Agency
now
believes
that
risks
for
golfers
are
not
of
concern
even
on
the
day
of
application.
The
Agency's
review
of
the
ARTF
data
is
found
in
"
PCNB:
HED
Revision
of
Golfer
Risk
Assessment,"
dated
March
6,
2006
and
can
be
accessed
at
http://
www.
regulations.
gov/,
Docket
Number
OPP­
2004­
0202.

Aggregate
Risk
The
aggregate
risk
assessment
for
PCNB
estimates
combined
risks
from
exposure
to
PCNB
via
all
means
other
than
occupational
exposures.
Risks
from
dietary
exposure
(
food
and
drinking
water)
and
exposures
from
non­
occupational
sources
(
e.
g.,
residential
uses)
are
aggregated.

Acute
Aggregate
Risk.
No
acute
human
health
risk
endpoint
has
been
identified
for
PCNB,
so
an
acute
aggregate
risk
assessment
was
not
conducted.

Short­
and
Intermediate­
term
Aggregate
Risk.
This
measure
of
aggregate
risk
combines
estimated
chronic
dietary
exposure
plus
any
applicable
residential,
recreational,
incidental
oral,
dermal,
and
inhalation
exposures.
For
PCNB,
residential
risks
from
contact
with
treated
lawns
by
themselves
are
of
concern.
These
risks,
combined
with
residential
handler
and
dietary
risks,
yield
aggregated
risk
estimates
of
even
greater
concern.
Mitigation
proposed
by
the
registrants
and
correction
and
refinement
of
the
dietary
assessment
focusing
on
the
contribution
of
milk
to
dietary
exposure
would
reduce
the
dietary
risk
below
levels
of
concern
for
the
general
population
and
all
subgroups.
Mitigation
proposed
by
the
registrants
would
eliminate
the
risk
from
residential
application
and
post­
application
exposures
related
to
the
turf
use;
risks
from
applications
to
residential
ornamentals
have
not
been
quantified,
but
the
Agency
remains
concerned
about
them.
The
original
aggregate
risk
assessment
is
discussed
in
Section
III
of
the
RED;
the
aggregate
assessment
based
on
the
registrant
risk
mitigation
proposal
is
discussed
in
Section
IV.

Chronic
Aggregate
Risk.
Since
none
of
the
residential
or
recreational
exposures
to
PCNB
are
considered
to
be
chronic
in
length
and
duration,
the
chronic
aggregate
risk
assessment
addresses
only
chronic
dietary
exposures
to
PCNB
in
food
and
water.
As
noted
above,
dietary
risks
from
food
plus
water
were
of
concern
for
several
highly
exposed
subpopulations.
Mitigation
measures
proposed
by
the
registrants
and
correction
and
refinement
of
the
dietary
assessment
would
reduce
the
chronic
dietary
risk
below
levels
of
concern
for
the
general
population
and
all
subgroups.
­
xiii
­
­
Cancer
Aggregate
Risk.
PCNB
is
classified
as
a
possible
human
carcinogen
(
Group
C).
The
dose­
response
relationship
is
unquantified.
The
Agency
believes
that
the
cPAD
chosen
for
predicting
chronic
dietary
risk
is
also
appropriate
for
quantifying
human
carcinogenic
risk,
so
a
separate
assessment
of
aggregate
cancer
risk
is
not
necessary.

Occupational
Risk
PCNB
is
used
to
treat
seed,
and
for
soil
and
foliar
applications.
Risks
to
handlers
for
all
types
of
applications
are
assessed.
Post­
application
risks
to
workers
are
assessed
for
those
workers
thought
to
have
the
highest
potential
for
exposure.

Occupational
Risk
(
excluding
seed
handlers)

The
Agency
assessed
potential
occupational
exposures
to
workers
for
exposure
scenarios
derived
from
the
various
use
sites,
formulation
types,
application
methods
and
rates,
and
tasks
performed
by
workers.
The
Agency
assessed
103
different
non­
seed
handler
exposure
scenarios
for
occupational
use.

Handler
MOEs
were
calculated
for
short­
and
intermediate­
term
exposures.
The
intermediate­
term
duration
is
intended
to
represent
commercial
applicators
who
may
make
repeated
applications
of
PCNB
over
the
course
of
the
growing
season,
while
the
short­
term
duration
is
representative
of
private
growers,
whose
exposures
during
the
season
are
likely
to
be
more
limited.
The
occupational
risk
assessment
includes
MOE
calculations
for
progressively
more
protective
levels
of
personal
protective
equipment
(
PPE)
and
engineering
controls,
using
surrogate
data
from
the
Pesticide
Handlers
Exposure
Data
(
PHED).
The
occupational
risk
assessment
is
described
in
more
detail
in
Section
III
of
this
document.
Although
the
registrants'
risk
mitigation
proposal
would
be
expected
to
decrease
some
occupational
risks
below
levels
of
concern,
no
formal
reassessment
of
occupational
risk
was
conducted.

Potential
handler
risk
for
each
exposure
scenario
was
assessed
using
the
endpoints
selected
from
the
toxicology
database
for
PCNB
and
the
appropriate
uncertainty
factor.
Risks
associated
with
different
levels
of
PPE
and
engineering
controls
were
assessed
independently
of
what
is
currently
required
by
PCNB
labels,
and
the
assessment
indicates
what
level
of
PPE
or
engineering
controls
would
be
required
to
adequately
mitigate
the
risks
associated
with
the
various
scenarios.

The
target
MOE
for
the
occupational
uses
of
PCNB
is
100.
Based
on
the
currently
labeled
uses
of
PCNB,
many
scenarios
do
not
achieve
MOEs
greater
than
100
at
any
level
of
PPE
or
engineering
controls,
or
data
are
not
available
to
assess
the
risk
reduction
associated
with
higher
levels
of
protection.
In
other
cases,
the
use
of
engineering
controls
is
not
feasible
and
was
not
assessed.
The
formulation
type
and
use
site
combinations
corresponding
to
MOEs
less
than
100
at
the
highest
level
of
protection
assessed
or
feasible
are:

Mixer/
loaders
­
xiv
­
­
°
dry
flowables/
chemigation/
sod
farms
(
MOEs
39­
80)
°
liquids/
chemigation/
sod
farms
(
inhalation
MOE
74)
°
wettable
powders/
chemigation/
soil
banding
cole
crops
(
inhalation
MOE
28)
°
wettable
powders/
chemigation/
sod
farms
(
inhalation
MOE
20)
°
wettable
powders/
groundboom/
sod
farms
(
inhalation
MOE
89)

Applicators
°
dry
flowables
as
spray/
high­
pressure
handwand/
ornamentals
(
MOEs
0.59­
39)
°
emulsifiable
concentrates
/
high­
pressure
handwand/
industrial
lawn
(
inhalation
MOE
59)
°
wettable
powders/
high­
pressure
handwand/
industrial
lawns
(
inhalation
MOE
18)

Mixer/
loader/
applicators
or
loader/
applicators
°
liquids/
handgun
sprayer/
ornamentals
(
MOEs
36­
77)
°
granules/
push­
type
spreader/
industrial
lawn
(
inhalation
MOE
44)
°
granules/
belly
grinder/
ornamentals
(
dermal
MOE
21)
°
granules/
push­
type
spreader/
ornamentals
(
inhalation
MOE
88)
°
wettable
powders/
low­
pressure
hand­
wand/
ornamentals
(
MOEs
0.58­
3.1)
°
wettable
powders/
low­
pressure
hand­
wand/
shade
trees
(
MOEs
3.4­
18)

The
occupational
scenarios
with
MOEs
less
than
100
include
most
of
the
scenarios
assessed
for
sod
farms.
Six
of
the
eight
mixer/
loader/
applicator
or
loader/
applicator
scenarios
for
which
occupational
risk
were
assessed
have
MOEs
of
100
or
less;
these
scenarios
all
involve
the
use
of
PCNB
on
ornamentals
and
lawns,
with
liquid,
granular,
and
wettable
powder
formulations.
Occupational
risks
associated
with
these
scenarios
cannot
be
adequately
mitigated
with
PPE
or
engineering
controls.
Risk
mitigation
measures
needed
to
address
other
risk
concerns
will
mitigate
most
of
the
occupational
risks
associated
with
use
of
PCNB
on
ornamentals,
and
any
remaining
risks
will
be
addressed
with
labeling
required
by
the
RED.

Occupational
Risk
for
Seed
Handlers
Seed
handler
exposures
vary
with
application
rates,
the
activities
in
which
handlers
engage,
whether
closed
systems
are
used
in
the
seed
treatment
facility,
and
the
amount
of
seed
handled.
These
latter
factors
are,
in
turn,
related
to
whether
PCNB
is
applied
commercially
or
onfarm
Activities
assessed
by
EPA
are
loading/
applying,
bagging,
sewing
bags
of
seed
closed,
planting,
and
multiple
seed
handling
tasks
performed
by
the
same
individual.
This
assessment
does
not
account
for
high­
efficiency
air­
handling
systems
facilities
that
remove
air
laden
with
pesticide
residues
from
the
workspace.
The
Agency
lacks
a
methodology
to
assess
such
systems,
but
believes
they
can
reduce
occupational
exposures
for
seed
handlers.
The
Agency
considers
seed­
handling
tasks
to
result
in
short­
and
intermediate­
term
exposures.

There
are
four
scenarios
in
which
risks
were
estimated
to
be
below
the
target
MOE
of
100;
all
four
are
the
result
of
inhalation
exposures
at
commercial
seed
treatment
facilities
for
handlers
engaged
in
multiple
treatment
activities,
with
barley
(
MOE
50),
peas
(
75),
rice
(
50),
and
soybeans
(
75).
These
scenarios
were
assessed
for
handlers
wearing
long
pants,
long­
sleeved
shirts,
gloves,
but
no
respirator,
and
using
open
systems.
While
data
are
lacking
to
quantify
risks
­
xv
­
­
for
seed­
handlers
engaged
in
multiple
treatment
activities
on
the
farm,
it
is
reasonable
to
assume
that
those
handlers
might
also
be
exposed
above
levels
of
concern.
The
Agency
has
determined
that
the
labels
of
PCNB
seed
treatment
products
must
be
amended
to
require
seed
handlers
to
wear
respirators
while
seed
handling
tasks
are
performed.
The
type
of
respirators
differs
by
the
type
of
task.

Post­
application
Worker
Risks
The
Agency
assessed
risks
for
the
workers
expected
to
be
most
highly
exposed
after
application
of
PCNB 
golf
course
maintenance
workers
and
sod
farm
workers.
There
were
no
risks
of
concern
associated
with
their
exposures.

Benefits
of
PCNB
use
EPA
assessed
the
benefits
and
costs
associated
with
the
use
of
PCNB
and
alternatives
for
the
major
uses
of
PCNB.
This
assessment
is
described
in
the
document,
"
Benefits
and
Cost
Analysis
of
PCNB
and
Alternatives
for
Use
on
Golf
Course
Turf
(
Tees,
Greens,
Fairways),
Cotton,
Potatoes,
Green
Beans,
and
Cole
Crops
(
Cabbage,
Brussels
Sprouts,
Cauliflower),
"
May
22,
2006,
which
has
been
posted
to
the
PCNB
Docket
at
http://
www.
regulations.
gov/.
EPA
has
also
sought
to
characterize
the
benefits
of
the
minor
uses
of
PCNB
by
soliciting
information
through
the
USDA
from
the
Regional
IPM
Centers,
and
by
examining
Crop
Profiles
posted
at
http://
www.
ipmcenters.
org/
Crop
Profiles/,
anecdotal
information
about
how
users
value
PCNB,
and
usage
and
percent
crop
treated
information.
The
benefits
assessments
are
detailed
in
Section
IV
of
this
RED.

The
Agency
has
concluded
that
of
the
major
use
sites,
only
the
use
of
PCNB
to
combat
clubroot
on
cole
crops
has
substantial
benefits.
PCNB
appears
to
be
the
only
available
chemical
treatment
that
is
feasible
for
effective
management
of
clubroot
where
the
pathogen
occurs
in
soil.
Both
methyl
bromide
and
metam
sodium
are
effective
in
controlling
the
pathogen,
but
both
pose
risks
of
concern.
A
six­
or
seven­
year
rotation
to
crops
in
another
plant
family
may
be
effective
for
controlling
the
pathogen
on
infested
acreage,
but
may
not
be
a
practical
alternative
for
growers.

While
acknowledging
that
additional
information
not
already
available
to
the
Agency
could
be
used
to
refine
the
benefits
assessment
for
the
minor
uses
of
PCNB,
the
Agency
additionally
has
identified
only
commercial
production
of
flowering
bulbs
and
seed
treatments
as
uses
with
potentially
high
benefits
from
the
use
of
PCNB.
The
Agency
is
actively
soliciting
comments
on
the
need
for
PCNB
on
some
other
minor
use
sites,
in
order
to
determine
if
amendments
should
be
made
to
this
eligibility
decision.

Risk
Mitigation
Summary
EPA
has
assessed
the
risks
associated
with
the
uses
of
PCNB
as
currently
labeled,
and
also
as
associated
with
the
mitigation
measures
proposed
by
the
technical
registrants.
While
implementation
of
the
registrants'
proposal
would
adequately
reduce
or
eliminate
dietary
and
­
xvi
­
­
most
residential
and
occupational
risks,
other
residential
and
occupational
risks
and
ecological
risks
would
continue
to
be
of
concern.
As
noted,
the
Agency
has
evaluated
the
benefits
of
PCNB
use,
and
has
made
a
determination
on
each
of
the
uses
of
PCNB
based
on
the
relationship
of
risks
to
benefits.
In
order
to
adequately
address
the
full
complement
of
PCNB
risks,
and
in
consideration
of
the
benefits,
the
Agency
has
decided
that
a
number
of
measures
are
necessary.
In
summary:

°
The
uses
of
PCNB
on
turf,
residential
ornamentals,
green
beans,
cotton,
potatoes,
dry
beans
and
peas,
garlic,
peanuts,
tomatoes,
peppers,
and
ornamentals
in
commercial
production
(
except
for
flowering
bulbs)
are
not
eligible
for
reregistration
and
must
be
deleted
from
product
labels.
Products
labeled
exclusively
for
one
or
more
of
these
ineligible
uses
will
not
be
eligible
for
reregistration.

°
Application
to
flowering
bulbs
in
commercial
production
must
be
limited
to
in­
furrow,
banded,
drench,
and
bulb
soak
applications.
Broadcast
application
to
ornamental
bulbs
is
prohibited.
Wettable
powder
formulations
must
not
be
labeled
for
this
use.

°
Products
which
are
eligible
for
reregistration
must
be
labeled
to
require
adequate
PPE
and
engineering
controls,
as
detailed
in
this
RED.
For
example,
seed
handlers
will
be
required
to
wear
PPE
for
respiratory
protection.

°
Application
to
cole
crops
must
be
limited
to
a
maximum
rate
of
22.5
lb
ai/
A.
Application
via
chemigation
is
prohibited.
Products
for
use
on
cole
crops
must
bear
labeling
prohibiting
their
use
on
cole
crops
except
for
treatment
of
clubroot.
The
only
products
labeled
for
use
on
cole
crops
which
are
eligible
for
reregistration
are
those
which
are
limited
to
the
cole
crop/
clubroot
combination,
and
no
other
pests
may
be
added
to
the
label
of
a
registered
product
either
by
amendment
or
through
the
notification
process
(
PR
Notice
98­
10).

°
All
aerial
applications
of
PCNB
are
prohibited.

These
eligibility
decisions,
and
the
risk
mitigation
measures
for
the
uses
which
have
been
designated
as
eligible
for
reregistration,
are
discussed
in
detail
in
Section
IV
of
this
RED.

Conclusions
The
risk
assessments
for
PCNB,
which
support
the
Agency's
reregistration
decision,
are
based
on
the
best
scientific
data
and
methodologies
available
to
the
Agency
at
this
time
and
are
adequate
for
determining
the
reregistration
eligibility
of
the
uses
of
PCNB
and
reassessing
tolerances.
The
benefits
associated
with
the
currently
labeled
uses
for
PCNB
are
also
a
factor
in
the
Agency's
decision.
Due
to
residual
uncertainty
associated
with
the
benefits
of
the
minor
uses
of
PCNB,
the
Agency
is
issuing
this
Reregistration
Eligibility
Decision
for
PCNB
for
a
60­
day
public
comment
period,
as
announced
in
a
Notice
of
Availability
published
in
the
Federal
Register.
The
RED
announces
the
Agency's
decision
that
the
following
uses
of
PCNB
are
eligible
for
reregistration:
cole
crops
(
for
treatment
of
clubroot
only),
ornamental
bulbs
in
­
xvii
­
­
commercial
production,
and
seed
treatments.
Other
uses
of
PCNB
are
not
eligible
for
reregistration.
The
RED
includes
guidance
and
time
frames
for
complying
with
required
label
changes
for
products
containing
PCNB
and
developing
data
required
to
support
the
eligible
uses.
­
1
­
­
I.
Introduction
The
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
was
amended
in
1988
to
accelerate
the
reregistration
of
products
with
active
ingredients
registered
prior
to
November
1,
1984,
and
amended
again
by
the
Pesticide
Registration
Improvement
Act
of
2003
to
set
time
frames
for
the
issuance
of
Reregistration
Eligibility
Decisions.
The
amended
Act
calls
for
the
development
and
submission
of
data
to
support
the
reregistration
of
an
active
ingredient,
and
a
review
of
all
submitted
data
by
the
U.
S.
Environmental
Protection
Agency.
Reregistration
involves
a
thorough
review
of
the
scientific
database
underlying
a
pesticide's
registration.
The
purpose
of
the
Agency's
review
is
to
reassess
the
potential
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
or
not
the
pesticide
meets
the
"
no
unreasonable
adverse
effects"
criteria
of
FIFRA.

On
August
3,
1996,
the
Food
Quality
Protection
Act
(
FQPA)
was
signed
into
law.
This
Act
amends
FFDCA
to
require
that
by
August
3,
2006,
EPA
must
reassess
all
tolerances
in
effect
at
the
time
of
the
enactment.
FQPA
also
amends
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)
to
require
a
safety
finding
in
tolerance
reassessment
based
on
factors
including
consideration
of
cumulative
effects
of
chemicals
with
a
common
mechanism
of
toxicity.

PCNB
is
an
organochlorine
fungicide
used
to
control
diseases
on
vegetables
(
especially
green
beans
and
cole
crops),
field
crops
(
cotton,
potatoes,
and
peanuts),
turf,
ornamentals,
and
seeds
(
seed
treatments
of
barley,
beans,
corn,
cotton,
oats,
peas,
peanut,
potato,
safflower,
sorghum,
soybean,
sugar
beet,
and
wheat).
It
is
applied
to
soil,
foliage
(
for
turf
and
some
ornamental
uses),
and
seeds.

The
Agency
has
concluded
that
the
FQPA
Safety
Factor
of
10X
must
be
retained
for
PCNB
dietary
and
residential
risk
estimates
because
there
are
residual
uncertainties
in
the
databases
for
pre­
and/
or
postnatal
toxicity.
The
decision
to
retain
the
10X
factor
takes
into
account
these
potential
effects
and
the
incompleteness
of
the
data
with
respect
to
exposure
and
toxicity
to
infants
and
children.
The
safety
factor
has
been
retained
for
the
assessment
of
dietary,
residential,
and
aggregate
risk.

Risks
summarized
in
this
document
are
those
that
result
only
from
the
use
of
PCNB.
FQPA
requires
that
the
Agency
consider
available
information
concerning
the
cumulative
effects
of
a
pesticide's
residues
and
other
substances
that
have
a
common
mechanism
of
toxicity.
The
reason
for
consideration
of
other
substances
is
due
to
the
possibility
that
low­
level
exposures
to
multiple
chemical
substances
that
cause
a
common
toxic
effect
by
a
common
toxic
mechanism
could
lead
to
the
same
adverse
health
effect
that
would
occur
at
a
higher
level
of
exposure
to
any
of
the
substances
individually.
Unlike
other
pesticides
for
which
EPA
has
followed
a
cumulative
risk
approach
based
on
a
common
mechanism
of
toxicity,
EPA
has
not
made
a
common
mechanism
of
toxicity
finding
for
PCNB
and
any
other
substances.
Chlorothalonil
and
pentachlorophenol,
pesticides
in
the
same
family
as
PCNB,
do
not
appear
to
result
in
the
same
endpoints.
The
endpoints
used
to
assess
human
health
risks
for
PCNB
are
primarily
thyroid
hypertrophy
and
hepatocellular
hypertrophy
and
hyperplasia.
The
endpoints
for
chlorothalonil
­
2
­
­
have
been
identified
as
various
kidney
and
forestomach
effects,
and
the
endpoints
for
pentachlorophenol
are
carcinogenicity
(
hemangiosarcomas,
hepatocellular
tumors,
and
adrenal
tumors)
and
developmental
effects
(
increased
resorptions
of
fetuses,
reduced
fetal
weight,
skeletal
malformations
of
fetuses).
The
Agency
has
not
undertaken
a
comprehensive
assessment
of
organochlorine
pesticides
with
respect
to
common
mechanism.
For
the
purposes
of
this
action,
EPA
assumes
that
PCNB
does
not
share
a
common
mechanism
of
toxicity
with
other
substances.
Information
on
EPA's
efforts
to
determine
which
chemicals
have
a
common
mechanism
of
toxicity
and
to
evaluate
the
cumulative
effects
of
such
chemicals
is
found
in
the
policy
statements
released
by
EPA's
Office
of
Pesticide
Programs
at
http://
www.
epa.
gov/
pesticides/
trac/
science/#
common.

This
document
presents
the
Agency's
reregistration
eligibility
decision
for
the
registered
uses
of
PCNB,
including
the
consideration
of
risk
to
infants,
children
and
adults
for
any
potential
food
and
drinking
water
exposures,
and
dermal,
inhalation
or
oral
exposures
from
residential
uses.
The
information
presented
herein
is
summarized
from
more
detailed
information
which
can
be
found
in
the
technical
supporting
documents
for
PCNB
referenced
in
this
document.
The
preliminary
and
revised
risk
assessments
and
supporting
documents
for
PCNB
may
be
accessed
via
http://
www.
regulations.
gov/,
the
Federal­
wide
electronic
docket
management
and
comment
system.
To
find
the
correct
docket
and
documents
associated
with
it,
select
the
Advanced
Search
function,
and
then
select
Docket
Search.
Enter
the
Docket
Number
OPP­
2004­
0202
in
the
Docket
ID
field
and
submit.
Click
on
the
Docket
ID
link,
and
icons
for
viewing
and
downloading
the
supporting
documents
will
appear.
Your
computer's
"
pop­
up
blocker"
function
must
be
turned
off
for
you
to
view
or
download
documents
in
the
docket.

This
document
consists
of
six
sections.
Section
I
is
this
Introduction.
Section
II
provides
a
Chemical
Overview,
a
profile
of
the
use
and
usage
of
PCNB,
and
its
regulatory
history.
Section
III,
Summary
of
the
PCNB
Risk
Assessments,
outlines
the
human
health
and
environmental
risks
associated
with
PCNB.
Section
IV
discusses
the
Agency's
Risk
Management,
Reregistration,
and
Tolerance
Reassessment
Decisions.
Section
V,
What
Registrants
Need
to
Do,
summarizes
changes
to
be
implemented
based
on
the
risk
mitigation
measures
discussed
in
Section
IV
and
generic
data
required
to
support
continued
registration
of
the
eligible
uses
of
PCNB.
Finally,
the
Appendices
in
Section
VI
list
all
use
patterns
eligible
for
reregistration,
bibliographic
information,
related
documents
and
how
to
access
them,
and
provide
the
Data
Call­
In
notices
(
DCIs)
associated
with
this
RED.

II.
Chemical
Overview
A.
Regulatory
History
PCNB
was
first
registered
in
the
United
States
in
l964.
There
are
74
active
registrations
for
products
containing
PCNB
registered
under
Section
3
of
FIFRA.
There
are
also
four
longstanding
Section
18
Emergency
Exemptions
and
eight
Section
24(
c)
(
Special
Local
Needs)
registrations.
This
RED
document
evaluates
risks
from
all
currently
registered
uses,
including
agricultural
food
and
non­
food
crops
and
non­
agricultural
uses
such
as
ornamentals
and
turf.
­
3
­
­
PCNB
has
been
identified
by
EPA
as
one
of
177
Hazardous
Air
Pollutants.
The
Agency
is
assisting
State
and
local
agencies
in
their
efforts
to
prioritize
these
pollutants
for
further
investigation.
PCNB
has
also
been
designated
as
toxic
air
contaminant
by
California,
and
so
is
subject
to
an
evaluation
of
potential
control
measures
and
an
effort
to
foster
public
awareness
of
potential
exposures
and
control
measures.

In
Canada,
PCNB
is
a
candidate
for
reevaluation
(
akin
to
our
reregistration).
In
2000,
the
sole
European
registrant
of
PCNB,
Uniroyal
(
now
Chemtura),
withdrew
support
for
the
fungicide
following
a
determination
by
the
European
Commission
that
risk
to
non­
target
organisms
could
not
be
excluded
by
evaluation
of
the
current
data
base.
Uniroyal
elected
not
to
develop
the
data
needed
to
support
the
registration,
primarily
ecotoxicology
and
environmental
fate
data.

B.
Chemical
Identification
°
Chemical
Structure:

NO2
Cl
Cl
Cl
Cl
Cl
°
Common
name:
PCNB,
quintozene
°
Chemical
name:
pentachloronitrobenzene
°
Chemical
Family:
organochlorine,
substituted
aromatics
class
°
Empirical
formula:
C
6
Cl5NO2
°
CAS
Registry
No.:
82­
68­
8
°
Case
number:
0128
°
OPP
Chemical
Code:
056502
°
Molecular
weight:
295.3
g/
mol
°
Trade
names:
Terraclor,
Turfcide,
Terrazan,
Terra­
Coat,
Parflo,
Win­
Flo,
Blocker
°
Basic
manufacturers:
Amvac,
Chemtura
(
formerly
Crompton
Corp.
or
Uniroyal)

Technical
PCNB
is
a
colorless
to
pale
yellow
to
cream­
colored
crystalline
solid
of
fine
needles.
It
is
practically
insoluble
in
water
(
0.44
mg/
l
at
25
°
C).
PCNB
has
a
melting
point
of
141­
145
°
C,
a
boiling
point
of
328
°
C,
and
a
relatively
high
vapor
pressure
(
1.13
x
10­
4
mmHg
at
25
°
C).
­
4
­
­
C.
Use
Profile
Use
information
for
PCNB
is
detailed
in
Appendix
A.

Type
of
Pesticide:
Fungicide
Summary
of
Use:
PCNB
is
a
non­
systemic
fungicide
applied
to
soil,
foliage
(
mainly
turf),
and
seeds
to
control
plant
diseases.
PCNB
may
be
formulated
with
other
fungicides
or
an
insecticide,
e.
g.,
thiram,
metalaxyl,
carboxin,
or
malathion.

Food
Uses:
PCNB
is
used
on
vegetables
(
predominantly
green
beans
and
cole
crops),
field
crops
(
cotton,
potatoes,
and
peanuts),
and
seeds
(
seed
treatments
of
barley,
beans,
corn,
cotton,
oats,
peas,
peanut,
rice,
safflower,
sorghum,
soybean,
sugar
beet,
and
wheat).
There
are
tolerances
for
PCNB
on
cottonseed,
collards,
kale,
mustard,
beans,
broccoli,
Brussels
sprouts,
cabbage,
cauliflower,
garlic,
pepper,
potato,
tomato,
and
peanuts.
Non­
Food:
PCNB
is
used
on
turf
(
golf
courses,
sod
farms,
commercial
and
industrial
turf,
and
lawns)
and
ornamentals.

Residential:
PCNB
is
used
on
lawns
and
broadleaf
ornamentals.

Target
Pests:
Cole
crops:
clubroot
(
Plasmodiophora
brassicae),
wirestem
(
Rhizoctonia
solani)
Cotton:
Rhizoctonia
seedling
disease
or
damping­
off
(
R.
solani)
Green
beans:
Rhizoctonia
root/
stem
rot
or
damping­
off
(
R.
solani),
white
mold
(
S.
sclerotiorum).
Peanuts:
seedling
diseases
(
R.
solani,
Fusarium
and
Pythium
spp.)
Potatoes:
stem
canker/
black
scurf
(
R.
solani),
white
mold
(
Sclerotinia
sclerotiorum)
Tomatoes
and
peppers:
Southern
blight
(
Sclerotium
rolfsii)
Turf:
Fusarium
patch
(
pink
snow
mold),
Typhula
blight
(
gray
snow
mold),
dollar
patch,
Rhizoctonia
brown
patch,
large
patch
of
Zoysia,
leaf
spot/
melting­
out
dollar
spot
PCNB
works
by
suppressing
the
growth
of
plant
pathogens.

Formulation
Types:
Flowable
concentrate,
water
dispersible
granular,
wettable
powder,
emulsifiable
concentrate,
granular,
dust,
and
ready­
to­
use
formulations
Application
Seed
treatment,
pre­
plant
incorporated
applications,
in­
furrow,
broadcast
Methods:
banding,
drenches,
foliar
sprays
­
5
­
­
Application
Rates:
Maximum
application
rates
for
field
and
vegetable
crops
are
generally
2­
30
lb.
ai/
A
with
one
application/
season.
The
maximum
label
rate
for
turf
is
33
lb.
ai/
A
per
application,
with
a
maximum
of
two
applications/
season.
PCNB
may
be
applied
as
an
unincorporated
broadcast
application
to
ornamental
bulbs
at
213
lb.
ai/
A,
the
highest
yearly
application
rate
for
PCNB.

Timing:
Primarily
at
or
near
planting;
for
snow
mold
on
turf,
in
cool,
damp
weather
Use
Classification:
General
Use
Registrants:
Include
Amvac
and
Chemtura
(
registrants
of
technical
material),
Bayer
Cropscience
LP,
Scotts,
Lebanon
Seaboard,
Syngenta,
VPG,
Drexel,
The
Andersons,
Gowan,
Lesco,
Marman
D.
Estimated
Usage
of
Pesticide
Table
1
summarizes
PCNB
usage
on
major
sites
in
the
United
States.

Table
1.
PCNB
Usage
Summary
Site
Lbs.
Active
Ingredient
Applied
Maximum
Percent
Crop
Treated
Cotton
400,000
10%

Turf
250,000­
500,000
no
information
Potatoes
60,000
5%

Green
beans
30,000
20%

Cabbage
10,000
<
2.5%

Cauliflower
6,000
5%

Brussels
sprouts
7,000
10%

Peanuts
5,000
<
2.5%

Total
770,000­
1,000,000
For
more
detail,
see
the
Screening
Level
Usage
Assessment
of
May
10,
2005,
posted
to
http://
www.
regulations.
gov/,
Docket
Number
OPP­
2004­
0202.

III.
Summary
of
PCNB
Risk
Assessments
­
6
­
­
This
section's
summary
of
EPA's
human
health,
environmental
fate,
and
ecological
effects
risk
findings
and
conclusions
for
PCNB
has
been
drawn
from
the
more­
detailed
documents:
"
Pentachloronitrobenzene
(
PCNB):
2nd
Revised
HED
Chapter
of
the
Reregistration
Eligibility
Decision
Document"
dated
February
3,
2005
(
the
chapter
was
revised
to
address
error­
only
comments
solicited
from
the
registrants),
and
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,"
February
15,
2005,
and
associated
supporting
documents
available
at
http://
www.
regulations.
gov/,
Docket
Number
OPP­
2004­
0202.
The
risk
estimates
presented
in
this
Section
reflect
the
Agency's
best
estimates
as
of
February
2005,
and
are
presented
here
for
reference
purposes.
Based
on
public
comments,
technical
corrections,
and
risk
mitigation
measures
proposed
by
the
registrants,
the
Agency
subsequently
revised
many
of
its
risk
assessments
for
PCNB.
These
changes
are
fully
discussed,
and
citations
for
supporting
scientific
documents
provided,
in
Section
IV
of
this
RED.

A.
Human
Health
Risk
Assessment
1.
Toxicity
of
PCNB
a)
Acute
Toxicity
The
database
for
acute
toxicity
of
the
technical
grade
PCNB
products
is
complete.
PCNB
has
relatively
low
acute
toxicity
to
the
test
animals.
Data
for
materials
produced
by
both
Chemtura
and
Amvac
are
presented
in
Table
2.
These
materials
differ
somewhat,
and
data
indicate
that
the
Chemtura
product
is
a
sensitizer
while
the
Amvac
product
is
not.

Table
2.
Acute
Toxicity
of
PCNB
Guideline
Number
Study
Type
Registrant
MRID
#
Results
Tox
Category
Chemtura
43198201
LD50
=
>
5000
mg/
kg
IV
81­
1/
870.1100
Acute
Oral
Amvac
41443101
LD50
=
>
5050
mg/
kg
IV
Chemtura
43198202
LD50
=
>
5000
mg/
kg
IV
81­
2/
870.1200
Acute
Dermal
Amvac
41443102
LD50
=
>
2020
mg/
kg
III
Chemtura
43118201
LC50
=
>
1.7
mg/
L
III
81­
3/
870.1300
Acute
Inhalation
Amvac
41443103
LC50
=
>
6.49
mg/
L
III
Chemtura
43198203
Slight
irritant
III
81­
4/
870.2400
Primary
Eye
Irritation
Amvac
41443109
Slight
irritant
III
81­
5/
870.2500
Chemtura
43198204
Non
irritant
IV
­
7
­
­
Primary
Skin
Irritation
Amvac
41443105
PII
=
0.0175
IV
Chemtura
40609001
Weak
sensitizer
n/
a
81­
6
/
870.2600
Dermal
Sensitization
Amvac
40734001
Non
sensitizer
n/
a
b)
Endpoint
Selection
The
toxicological
endpoints
used
for
the
human
risk
assessment
are
presented
in
Table
3
below.
Further
details
on
the
toxicity
database
of
PCNB
can
be
found
in
the
Docket
item
"
Revised
Toxicology
Disciplinary
Chapter
for
the
Reregistration
Eligibility
Decision,"
dated
January
7,
2005,
and
posted
to
http://
www.
regulations.
gov/.

Table
3.
Endpoints
for
PCNB
Risk
Assessment
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
FQPA
Safety
Factor)
Levels
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
N/
A
N/
A
None
selected
Chronic
Dietary
NOAEL=
1.0
mg/
kg/
day
(
10X)
cPAD
is
0.001
mg/
kg/
day
Target
is
 
100%
of
cPAD
Chronic/
Oncogenicity
Study
(
rat)
LOAEL
=
150
mg/
kg/
day
based
on
hepatocelluar
hypertrophy
and
hyperplasia,
thyroid
hypertrophy
Short­
Term
Incidental
Oral
(
1­
30
days)
NOAEL=
1.0
mg/
kg/
day
(
10X)
Target
MOE
 
1000
90­
Day
Subchronic
(
rat)

LOAEL
=
1.0
mg/
kg/
day,
based
on
no
toxicity
at
30d
Intermediate­
Term
Incidental
Oral
(
1­
6
months)
NOAEL=
1.0
mg/
kg/
day
(
10X)
Target
MOE
 
1000
90­
Day
Subchronic
(
rat)

LOAEL
=
1.0
mg/
kg/
day
based
on
threshold
effects
(
liver
and
thyroid
lesions)
seen
at
lowest
dose
tested
Short­
and
Intermediate­
Term
Dermal
NOAEL=
300
mg/
kg/
day
(
10X,
residential)
Residential
target
MOE
 
1000;
Occupational
target
MOE
>
100
21­
Day
Dermal
(
rat)
LOAEL
=
1000
mg/
kg/
day
based
on
hypertrophy
of
the
thyroid
follicular
epithelium
and
dilation
of
the
thyroid
follicles
in
males
Long­
Term
Dermal
(>
6
months)
Oral
NOAEL=
1.0
mg/
kg/
day;
dermal
absorption
33%
of
oral
Target
MOE
 
100
Chronic/
Oncogenicity
Study
(
rat)
LOAEL
=
150
mg/
kg/
day
based
on
hepatocelluar
hypertrophy
and
hyperplasia,
thyroid
hypertrophy
­
8
­
­
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
FQPA
Safety
Factor)
Levels
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Short­
Term
Inhalation
Oral
NOAEL=
1.0
mg/
kg/
day;
inhalation
absorption
100%
of
oral
(
10X,
residential)
Residential
target
MOE
 
1000;
Occupational
target
MOE
>
100
90­
Day
Subchronic
(
rat)
LOAEL
=
1.0
mg/
kg/
day
based
on
no
toxicity
at
30
days
Intermediate­
Term
Inhalation
Oral
NOAEL=
1.0
mg/
kg/
day;
inhalation
absorption
100%
of
oral
(
10X,
residential)
Residential
target
MOE
 
1000;
Occupational
target
MOE
 
100
90­
Day
Subchronic
(
rat)
LOAEL
=
1.0
mg/
kg/
day
based
on
threshold
effects
(
liver
and
thyroid
lesions)
seen
at
lowest
dose
tested
Long­
Term
Inhalation
Oral
NOAEL=
1.0
mg/
kg/
day
with
inhalation
absorption
rate
=
100%
of
oral
Target
MOE
 
100
Chronic/
Oncogenicity
Study
(
rat)
LOAEL
=
150
mg/
kg/
day
based
on
hepatocelluar
hypertrophy
and
hyperplasia,
thyroid
hypertrophy
Cancer
PCNB
is
classified
as
a
Group
C
(
possible
human)
carcinogen.
For
the
purpose
of
risk
characterization,
the
chronic
dietary
risk
assessment
approach
is
used
to
quantify
cancer
risk.

c)
FQPA
Safety
Factor
There
is
no
quantitative
or
qualitative
evidence
of
increased
susceptibility
of
rat
or
rabbit
fetuses
after
in
utero
exposure,
or
after
pre­
or
postnatal
exposure
to
rats
in
multigeneration
reproduction
studies.

Because
thyroid
weights
were
increased
in
a
number
of
chronic
and
subchronic
studies
in
rats;
thyroid
histopathology
effects
including
neoplasia
were
observed
in
some
studies;
and
TSH,
T3,
and
T4
levels
were
affected
in
a
90­
day
special
oral
study
in
male
rats,
the
Agency
determined
that
a
comparative
thyroid
assay
in
young
and
adult
rats
(
which
would
report
hormonal
measurements
for
thyroid
function)
would
be
required.
The
DCI
associated
with
this
RED
requires
that
such
a
study
be
undertaken
in
support
of
continued
registration
of
the
eligible
uses
of
PCNB.

The
absence
of
comparative
thyroid
study
data
at
this
time
introduces
an
extra
uncertainty
in
the
risk
assessment.
Thus,
the
Agency
has
determined
that
an
FQPA
safety
factor
of
10X
should
be
retained
for
the
dietary
(
chronic)
and
all
residential
exposure
(
incidental
oral,
dermal,
and
inhalation)
scenarios,
based
on
the
concern
about
thyroid
effects.

d)
Population
Adjusted
Dose
Dietary
risk
is
expressed
as
a
percentage
of
a
maximum
acceptable
dose
(
i.
e.,
the
dose
which
will
result
in
no
unreasonable
adverse
health
effects).
This
dose
is
referred
to
as
the
population
adjusted
dose
(
PAD).
The
PAD
is
equivalent
to
the
Reference
Dose
(
RfD)
divided
by
the
FQPA
Safety
Factor,
and
for
non­
cancer
effects,
is
of
concern
for
PCNB
at
or
above
100%.
­
9
­
­
(
1)
Acute
PAD
No
appropriate
acute
endpoint
attributed
to
a
single
dose
was
identified;
therefore,
an
acute
PAD
has
not
been
calculated.

(
2)
Chronic
PAD
The
endpoint
for
the
chronic
dietary
assessment
was
identified
in
a
combined
chronic
toxicity
and
oncogenicity
study
in
rats,
in
which
the
NOAEL
was
1.0
mg/
kg/
day
(
adverse
effects
observed
at
higher
doses
were
hepatocelluar
hypertrophy
and
hyperplasia,
and
thyroid
hypertrophy).
With
incorporation
of
the
intra­
and
interspecies
uncertainty
factors
(
totaling
100X),
the
chronic
RfD
is
then
0.01
mg/
kg/
day.
The
FQPA
Safety
Factor
is
10X,
as
discussed
above,
producing
a
chronic
PAD
of
0.001
mg/
kg/
day
(
cPAD
=
cRfD/
FQPA
SF).

e)
Uncertainties
in
the
Toxicology
Database
to
be
Addressed
with
New
Data
Requirements
The
fate
characteristics
of
PCNB
and
its
metabolites
indicate
that
they
have
the
potential
to
bioaccumulate.
The
extent
to
which
PCNB
and
its
metabolites
may
bioaccumulate
in
humans
is
a
source
of
uncertainty
and
concern
in
the
consideration
of
both
human
health
and
ecological
risks.
Data
are
required
to
address
this
uncertainty.
In
addition,
data
are
required
to
address
concerns
about
the
impact
of
contaminants
in
PCNB
test
materials
on
toxicity
testing,
and
additional
toxicity
endpoints.
Data
requirements
are
tabulated
in
Section
IV
of
this
RED.

2.
Dietary
Risk
Assessment
a)
Assumptions
and
Uncertainties
The
Agency
considers
the
dietary
risk
assessment
for
PCNB
to
be
a
highly
refined
assessment
that
utilizes
all
available
monitoring
data,
percent
crop
treated
information,
and
processing
factors.
Nevertheless,
several
important
assumptions
add
uncertainty
to
the
findings.

Because
monitoring
data
do
not
include
analysis
of
all
the
PCNB
metabolites
of
concern
(
there
are
more
than
80),
estimates
of
total
residues
of
concern
are
based
mainly
on
the
ratio
of
total
radioactive
residues
(
TRR)
to
PCNB
from
available
metabolism
studies
in
combination
with
monitoring
residue
data
on
PCNB.

USDA's
1994­
1998
Continuing
Surveys
of
Food
Intake
by
Individuals
were
used
as
the
consumption
database
for
the
dietary
exposure
assessment.
PCNB
and/
or
its
metabolites
were
widely
detected
in
monitoring
of
unregistered
food
uses,
often
at
levels
higher
than
in
registered
food
uses.
The
Agency
believes
that
the
presence
of
PCNB
and/
or
its
metabolites
on
unregistered
crops
is
due
primarily
to
its
uptake
from
soil
by
crops
planted
to
areas
where
other
crops
were
legally
and
previously
treated
with
PCNB
(
rather
than
illegal
use)
and
the
very
long
half­
lives
of
­
10
­
­
PCNB
and
its
metabolites
in
soil.
To
account
for
these
residues,
the
Agency
assessed
dietary
risk
for
residues
associated
with
registered
food
uses
only
and
for
residues
from
registered
food
uses
plus
residues
from
crops
for
which
PCNB
is
not
registered.
The
Agency
views
that
this
latter
set
of
residues
as
a
more
accurate
representation
of
dietary
exposure.
The
estimates
for
dietary
risk
from
food
found
in
this
document
are
based
on
residues
from
registered
crops
plus
residues
from
crops
for
which
PCNB
is
not
registered,
unless
otherwise
noted.

PCNB
and/
or
some
of
its
metabolites
have
been
found
at
detectable
levels
in
some
crop
parts
grown
from
treated
seeds,
particularly
wheat
(
straw)
and
peas.
Residues
have
also
been
found
in
these
same
crops
grown
from
untreated
seeds.
The
source
of
the
PCNB
residues
in
such
commodities
is
not
clear
and
may
vary.
Because
of
this
uncertainty
and
the
expectation
that
residues
resulting
from
seed
treatments
are
lower
than
those
resulting
from
soil
and
foliar
applications,
PCNB
residues
that
originate
with
seed
treatments
are
not
included
in
the
dietary
risk
assessment,
with
the
exception
of
such
residues
correlating
to
animal
feed
items.
The
seed
treatment
residues
are
an
important
component
of
residues
of
PCNB
and
metabolites
in
meat
and
milk
because
the
seed
treatment
uses
are
major
contributors
to
residues
in
animal
diets
(
animal
feed
items
are
mainly
associated
with
crops
for
which
PCNB
is
applied
to
seeds
only).

The
dietary
exposure
assessment
for
food
only
was
conducted
using
the
Dietary
Exposure
Evaluation
Model­
Food
Consumption
Intake
Database
(
DEEM­
FCID
 
)
.

b)
Acute
Dietary
Risk
Since
no
acute
endpoint
was
identified
for
PCNB,
an
acute
dietary
risk
assessment
was
not
conducted.

c)
Chronic
(
Noncancer)
Dietary
Risk
Table
4
shows,
that
in
February
2005,
chronic
dietary
risk
from
food
alone
was
estimated
at
over100%
of
the
cPAD
for
the
population
subgroups
children
1­
2
years
old
and
children
3­
5
years
old.
These
risk
estimates
are
associated
with
the
currently
registered
uses
of
PCNB
plus
residues
in
commodities
associated
with
uses
that
are
not
registered.
­
11
­
­
Table
4.
Chronic
Dietary
Risk
Estimates,
February
2005
Food
only
risk
(
no
water)
Total
risk
including
risk
from
water
Population
Subgroup
cPAD
(
mg/
kg/
day)
Exposure
(
mg/
kg/
day)
%
cPAD
Exposure
(
mg/
kg/
day)
%
cPAD
General
U.
S.
Population
0.001
0.000338
34
0.000703
70
All
Infants
(<
1
year
old)
0.001
0.000539
54
0.001734
173
Children
1­
2
years
old
0.001
0.001597
160
0.002138
214
Children
3­
5
years
old
0.001
0.001035
104
0.001542
154
Children
6­
12
years
old
0.001
0.000614
61
0.000964
96
Youth
13­
19
years
old
0.001
0.000281
28
0.000544
54
Adults
20­
49
years
old
0.001
0.000194
19
0.000535
54
Adults
50+
years
old
0.001
0.000206
21
0.000565
56
Females
13­
49
years
old
0.001
0.000203
20
0.000542
54
Chronic
dietary
risks
now
have
been
reassessed
based
on
proposed
mitigation
and
technical
revisions
to
correct
an
error
related
to
how
PCNB
residues
partition
in
the
liquid
and
fat
portions
of
milk
and
to
refine
the
dietary
assessment
by
more
accurately
reflecting
the
composition
of
the
diet
for
lactating
cows
and
its
contribution
to
residues
in
milk.
These
risk
estimates
are
discussed
in
Section
IV
of
this
document.

d)
Cancer
Dietary
Risk
PCNB
is
classified
as
an
unquantified
Group
C
(
possible
human)
carcinogen,
with
a
threshold
effect
observed
in
test
animals.
The
Agency
believes
that
the
cPAD
chosen
for
predicting
chronic
dietary
risk
is
also
appropriate
for
quantifying
human
carcinogenic
risk
from
PCNB
exposure.

e)
Dietary
Exposures
from
Drinking
Water
The
Agency
uses
physical­
chemical
property
data
and
representative
high­
application
rate
use
scenarios
to
model
potential
concentrations
of
pesticides
in
surface
water
and
groundwater,
or
Estimated
Drinking
Water
Concentrations
(
EDWCs).
For
drinking
water,
the
Agency
was
able
to
model
potential
contributions
from
PCNB
and
one
metabolite,
PCA.
Of
the
numerous
degradates
of
PCNB,
only
PCA
is
expected
to
be
present
at
>
10%
of
the
original
parent
concentration.
­
12
­
­
To
assess
concentrations
of
PCNB
and
PCA
in
drinking
water,
the
Agency
approximated
half­
lives
by
summing
the
concentration
of
the
parent
and
PCA;
half­
lives
were
calculated
normally
(
using
first­
order
linear
regression).
Degradation
kinetics
for
the
parent
and
PCA
were
not
determined
separately
and
then
combined.
This
approach
is
conservative,
but
should
not
overestimate
half­
lives
relative
to
estimates
determined
using
individual
kinetic
rates
for
each
compound.
The
continuous
formation
and
decline
of
degradates
in
a
sequential
manner
does
not
affect
the
half­
lives
calculated
using
this
approach,
as
the
other
major
degradate,
PCTA,
is
formed
from
PCA.

The
drinking
water
exposure
assessment
is
based
on
the
uses
of
PCNB
as
currently
labeled.
Other
features
of
the
drinking
water
exposure
assessment
are
detailed
in
"
Pentachloronitrobenzene,
Second
Revised
Drinking
Water
Assessment:
New
Tier
II
Drinking
Water
EDWCs
for
Use
in
the
Human
Health
Risk
Assessment,"
July
15,
2004,
accessible
via
http://
www.
regulations.
gov/.

Dietary
exposures
from
surface
water
are
incorporated
into
the
"
Total
risk
including
risk
from
water"
column
of
Table
4.
The
Agency
believes
that
surface
water
sources
are
more
likely
to
be
contaminated
with
PCNB
and
its
metabolites
than
are
groundwater
sources,
since
PCNB
is
relatively
immobile
in
soil.

(
1)
Surface
Water
Concentrations
Surface
water
EDWCs
were
determined
using
the
Tier
II
screening
models
PRZM/
EXAMS.
Applications
to
turf,
peanuts,
cabbage,
potatoes,
and
cotton
were
modeled,
with
the
turf
scenario
assessed
at
32.67
lb
ai/
A/
application,
and
two
applications,
for
the
highest
rate
overall.
This
scenario
produced
the
highest
EDWCs,
as
seen
in
Table
5
below.
Dietary
exposures
from
surface
water­
source
drinking
water
are
incorporated
into
Table
4.
Estimated
drinking
water
concentrations
don't
reflect
an
alternate
adsorption
coefficient
used
in
the
later
drinking
water
assessment
that
was
conducted
to
assess
the
registrants'
risk
mitigation
proposal.
The
Agency
used
a
different
coefficient
at
that
time
based
on
technical
comment
from
the
registrants;
the
new
coefficient
decreased
estimates
of
PCNB
getting
to
surface
water
to
a
small
degree
relative
to
the
impact
of
the
risk
mitigation
measures
themselves.

(
2)
Groundwater
Concentrations
Groundwater
EDWCs
for
the
drinking
water
assessment
were
generated
using
the
Tier
1
screening
model
SCI­
GROW.
The
highest
application
rate
from
PCNB
product
labels
was
used
as
an
input
in
the
model.
That
rate
is
the
application
to
bulb
crops
at
213.4
lb
ai/
A/
application
in
a
single
application.

Results
for
the
PRZM/
EXAMS
and
SCI­
GROW
modeling
are
shown
in
Table
5
below.
­
13
­
­
Table
5.
Chronic
(
1­
in­
10­
year
annual
mean
)
EDWCs,
February
2005
Source
Scenario
Modeled
EDWC
Surface
water
Turf
65.5
µ
g/
L
(
ppb)

Groundwater
Bulbs
30.6
µ
g/
L
(
ppb)

Drinking
water
concentrations
have
been
reassessed
based
on
mitigation
measures
proposed
by
the
registrants.
These
concentrations
are
discussed
in
Section
IV
of
this
document.

3.
Residential
and
Other
Nonoccupational
Exposures
PCNB
is
used
on
residential
turf,
and
to
a
lesser
extent,
broadleaf
ornamentals.
Individuals
who
apply
PCNB
in
their
yards
(
residential
handlers)
and
adults
and
children
who
do
yard
work,
or
walk,
sit,
play,
or
exercise
on
turf
to
which
PCNB
is
applied
may
be
exposed
to
residues.
The
Agency
has
assessed
the
potential
exposures
and
risks
associated
with
PCNB
applications
to
residential
turf.
PCNB
is
also
used
extensively
on
golf
courses,
and
the
Agency
has
assessed
the
potential
exposure
of
golfers
to
PCNB
residues
and
the
associated
risks.

a)
Residential
Handlers
(
1)
Exposure,
Scenarios,
and
Assumptions
Residential
handler
exposures
are
a
function
of
the
formulation
type,
application
equipment
and
rate,
and
area
treated
or
volume
applied.
The
Agency
assessed
eight
different
scenarios
deemed
to
be
representative
of
residential
applications
and
supported
by
exposure
data.

For
PCNB,
the
Agency
relied
on
assumptions
typical
to
most
residential
handler
assessments:

°
Homeowner
use
of
the
pesticide
is
episodic;
exposures
are
short­
term
°
Shorts,
short­
sleeved
shirts,
socks,
and
shoes
are
worn
during
application
°
One
person
mixes,
loads,
and
applies
the
pesticide
°
Area
treated
or
volume
applied
is
based
on
typical
lawn
sizes
°
Unit
exposure
values
from
PHED
or
from
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
data
were
used
to
calculate
risk,
based
on
scenarios
that
are
similar
but
not
identical
to
the
actual
scenarios.

(
2)
Residential
Handler
Risk
Estimates
The
risk
estimates
are
presented
in
Table
6
below.
Exposure
scenarios
are
described
in
greater
detail
in
the
document
"
Pentachloronitrobenzene
(
PCNB):
Revised
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document,
November
­
14
­
­
11,
2004."
The
residential
handler
risk
assessment
is
based
on
the
uses
of
PCNB
as
currently
labeled.
MOEs
representing
risks
of
concern
(<
1000)
are
shown
in
bold.

Table
6.
Summary
Short
Term
Residential
Handler
Risk
for
PCNB
Exposure
Scenario
Application
Rate
Area
Treated
or
Amounted
Applied
per
Day
Dermal
MOE
Inhalation
MOE
Applicator
Applying
Granulars
for
Hand
application
32.67
lb
ai
/
A
0.023
A
65
200
Mixer/
Loader/
Applicator
Liquids
for
Low
Pressure
Handwand
application
0.15
lb
ai
/
gal
5
gal
280
3100
Liquids
for
Backpack
sprayer
application
0.15
lb
ai
/
gal
5
gal
5500
3100
Liquids
for
Garden
hose­
end
sprayer
32.67
lb
ai
/
A
0.5
A
120
250
Loader/
Applicator
RTU
Liquids
for
Garden
hose­
end
sprayer
32.67
lb
ai
/
A
0.5
A
490
390
Granulars
for
Belly
Grinder
application
32.67
lb
ai
/
A
0.5
A
12
69
32.67
lb
ai
/
A
0.5
A
1900
4900
Granulars
for
Push­
type
spreader
43.56
lb
ai
/
A
0.5
A
1400
3700
b)
Residential
Post­
application
Risk
(
1)
Exposure,
Scenarios,
and
Assumptions
Residential
post­
application
exposures
result
primarily
from
contact
with
lawn
grass
after
treatment.
They
are
a
function
of
the
type
of
activity
taking
place
on
the
lawn
(
children
playing,
adults
doing
yard
work),
the
route
of
exposure
(
dermal,
hand­
to­
mouth),
application
rate,
and
time
since
treatment.
The
type
of
activity
and
the
route
of
exposure
combine
to
describe
the
scenario.

Exposure
estimates
are
based
on
standard
Transfer
Coefficients
(
TCs)
representing
the
amount
of
treated
surface
an
individual
is
likely
to
come
into
contact
with
during
an
hour
of
a
particular
type
of
activity.
The
coefficients
used
in
this
assessment
are
based
on
the
Policy
Memos
and
Standard
Operating
Procedures
cited
below.
Activities
(
on
turf)
selected
as
the
basis
for
the
residential
post­
application
risk
assessment
and
the
relevant
TCs
for
the
short­
term
endpoint
are:
­
15
­
­
°
Adults
in
a
low
exposure
activity
(
e.
g.,
golfing
or
mowing);
TC
=
500
cm2/
hour;
Policy
Memo
#
003.1
"
Agricultural
Transfer
Coefficients,"
Revised
August
7,
2000.

°
Adults
in
a
high
exposure
activity
(
e.
g.,
heavy
yard
work);
TC
=
14,500
cm2/
hour;
"
Recommended
Revisions
to
the
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments,"
Feb.
22,
2001.

°
Toddlers
in
a
high
exposure
activity
(
playing);
TC
=
5200
cm2/
hour;
SOPs
of
February
22,
2001.

The
proportion
of
residues
which
may
be
transferred
to
humans
from
treated
foliage,
designated
"
Turf
Transferable
Residues"
(
or
TTRs)
is
assumed
to
be
5%
of
the
PCNB
application
rate,
as
prescribed
by
the
February
22,
2001
SOP.

(
2)
Post­
application
Risk
Estimates
Dermal
risk
estimates
for
adults
and
children
exposed
to
PCNB
on
turf,
and
associated
with
the
use
of
PCNB
as
currently
labeled,
are
shown
in
Table
7.
MOEs
representing
risks
of
concern
(<
1000)
are
in
bold.

Table
7.
Risks
for
Residential
Short­
Term
Post­
Application
Activities
Activity
Application
Rate
(
lb
ai/
A)
TC
(
cm2/
hr)
MOE
on
day
of
treatment
high
contact
lawn
activities:
adults
32.67
14500
40
high
contact
lawn
activities:
toddler
32.67
5200
110
mowing
turf:
adults
32.67
500
1145
The
MOEs
for
all
but
one
of
the
assessed
residential
post­
application
scenarios
are
of
concern.
In
the
February
2005
assessment,
MOEs
calculated
for
reentry
of
treated
golf
courses
by
golfers
did
not
rise
above
1000
until
the
ninth
day
after
treatment.
However,
based
on
ARTF
data
received
after
this
assessment
was
completed,
golfer
reentry
risks
now
appear
to
be
acceptable
(
MOE
>
1000)
even
on
the
day
of
application.
The
ARTF
data
allowed
the
Agency
to
use
an
empirical
value
for
the
amount
of
residue
on
turf
which
is
available
for
transfer
to
human
skin
(
Turf
Transferable
Residue
or
TTR)
rather
than
a
default
value
which
is
5%
of
the
pesticide
application
rate.
The
empirical
value
was
less
than
the
default
value.
This
new
assessment
is
documented
in
"
PCNB:
HED
Revision
of
Golfer
Risk
Assessment,"
March
6,
2006,
which
has
been
posted
to
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202,
and
discussed
in
Section
IV
of
this
RED.

The
Agency
also
assessed
oral,
non­
dietary
exposure
to
toddlers
on
treated
turf.
Exposures
were
calculated
based
on
the
methodology
presented
in
the
residential
SOPs.
Postapplication
risk
estimates
for
PCNB
are
described
in
greater
detail
in
the
November
15,
2004
­
16
­
­
document
"
Revised
Occupational
and
Residential
Exposure
Assessment
for
the
[
PCNB]
Reregistration
Eligibility
Decision
Document,"
and
summarized
in
Table
8.
These
risks
were
assessed
based
on
the
use
of
PCNB
as
currently
labeled.
MOEs
representing
risks
of
concern
(<
1000)
appear
in
bold.

Table
8.
Residential
Short­
term
Post­
application
Risks
for
Toddlers
Exposure
Scenario
Application
Rate
MOE
Hand
to
Mouth
Activity
on
Turf
32.67
2
Object
to
Mouth
Activity
on
Turf
32.67
8
Incidental
Soil
Ingestion
32.67
612
Residential
post­
application
risks
have
been
reassessed
based
on
a
risk
mitigation
proposed
by
the
registrants,
as
discussed
in
Section
IV
of
this
RED.

4.
Aggregate
Risk
Short­
term
(
1­
30
day)
aggregate
exposure
combines
the
chronic
estimated
dietary
exposure
with
estimated
short­
term
residential/
recreational/
incidental
oral,
dermal,
and
inhalation
exposures
resulting
from
the
registered
uses
of
the
chemical.
Residential
handler
exposures
to
PCNB
are
considered
to
be
short­
term
due
to
episodic
use.
Likewise,
post­
application
exposures
are
considered
to
be
short­
term.
For
PCNB,
residential
exposures
are
already
of
concern,
so
aggregating
them
with
dietary
exposures
would
yield
risks
of
even
greater
concern.
Aggregate
risks
have
been
reassessed
based
on
proposed
mitigation,
as
discussed
in
Section
IV
of
this
RED.

5.
Cumulative
Assessment
FQPA
requires
EPA
to
consider
available
information
concerning
the
cumulative
effects
of
a
particular
pesticide's
residues
and
"
other
substances
that
have
a
common
mechanism
of
toxicity"
when
considering
whether
to
establish,
modify,
or
revoke
a
tolerance.
Potential
cumulative
effects
of
chemicals
with
a
common
mechanism
of
toxicity
are
considered
because
low­
level
exposures
to
multiple
chemicals
causing
a
common
toxic
effect
by
a
common
mechanism
could
lead
to
the
same
adverse
health
effect
as
would
a
higher
level
of
exposure
to
any
one
of
these
individual
chemicals.

Guidance
for
conducting
cumulative
risk
assessments
on
substances
that
have
a
common
mechanism
of
toxicity
is
available
at
http://
www.
epa.
gov/
pesticides/
trac/
science/#
common.
In
the
guidance,
it
is
stated
that
a
cumulative
risk
assessment
of
substances
that
cause
a
common
toxic
effect
by
a
common
mechanism
will
not
be
conducted
until
an
aggregate
exposure
assessment
of
each
substance
has
been
completed.
Before
undertaking
a
cumulative
risk
assessment,
HED
will
follow
procedures
for
identifying
chemicals
that
have
a
common
mechanism
of
toxicity
as
set
forth
in
the
"
Guidance
for
Identifying
Pesticide
Chemicals
and
Other
Substances
that
Have
a
Common
Mechanism
of
Toxicity"
(
64
FR
5795­
5796,
February
5,
1999).
­
17
­
­
PCNB
is
a
member
of
the
substituted
aromatics
class
of
pesticides
(
George
W.
Ware,
The
Pesticide
Book,
Fourth
ed.,
1994).
Other
members
of
this
class
include
chlorothalonil
and
pentachlorophenol.
The
Agency
did
not
perform
a
cumulative
risk
assessment
as
part
of
this
risk
assessment
for
PCNB.
Chlorothalonil
and
pentachlorophenol
do
not
appear
to
result
in
the
same
endpoints
as
PCNB.
The
endpoints
used
to
assess
human
health
risks
for
PCNB
are
primarily
thyroid
hypertrophy
and
hepatocellular
hypertrophy
and
hyperplasia.
The
endpoints
for
chlorothalonil
have
been
identified
as
various
kidney
and
forestomach
effects,
and
the
endpoints
identified
for
pentachlorophenol
are
carcinogenicity
(
hemangiosarcomas,
hepatocellular
tumors,
and
adrenal
tumors)
and
developmental
effects
(
increased
resorptions
of
fetuses,
reduced
fetal
weight,
skeletal
malformations
of
fetuses).
The
Agency
has
not
undertaken
a
comprehensive
assessment
of
organochlorine
pesticides
with
respect
to
common
mechanism.

6.
Occupational
Risk
Occupational
handlers
of
PCNB
may
be
exposed
through
seed
treatment
activities
or
the
use
of
PCNB
for
soil
and
foliar
applications.
Occupational
exposure
was
assessed
based
on
maximum
allowable
label
rates.
The
Agency
relied
on
surrogate
data
from
the
Pesticide
Handlers
Exposure
Database
(
PHED)
Version
1.1.;
chemical
specific
post­
application
exposure
data
have
not
been
submitted
by
the
registrants
in
support
of
the
reregistration
of
PCNB.

a)
Toxicological
Endpoints
for
the
Occupational
Assessment
Table
3
above
shows
the
endpoints
used
in
the
PCNB
occupational
risk
assessment.

b)
Seed
Handler
Exposure
Information
The
information
used
by
the
Agency
to
assess
exposures
to
handlers
of
treated
seed
comes
from
several
sources:

°
The
amount
of
seed
treated
or
planted
daily
is
based
on
information
from
an
Agency
database
and
from
registrants.
°
The
seed
treatment
exposure
SOP
unit
exposure
values
generally
range
from
the
geometric
mean
to
the
median
for
the
selected
data
set.
°
The
seed
treatment
surrogate
exposure
database
is
relatively
small.

c)
Soil
and
Foliar
Application
Exposure
Information
The
information
used
by
the
Agency
to
assess
exposures
to
handlers
from
soil
and
foliar
application
of
PCNB
also
comes
from
several
sources:

°
The
numbers
of
acres
treated
daily
are
standard
values
from
Exposure
Policy
Number
9.1,
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,"
September
25,
2001,
except
for
airblast
acreage
for
magnolia
trees.
For
this
assessment,
magnolia
acreage
is
assumed
at
20
acres.
­
18
­
­
°
The
unit
exposure
values
calculated
by
PHED
generally
range
from
the
geometric
mean
to
the
median
of
the
selected
data
set.

°
To
enhance
consistency
and
quality
control,
the
Agency
has
developed
a
set
of
grading
criteria
to
characterize
the
quality
of
the
original
study
data
from
the
PHED
database,
based
on
the
number
of
observations
and
the
available
quality
control
data.

°
While
data
from
PHED
provides
the
best
available
information
on
handler
exposures,
some
aspects
of
the
included
studies
may
not
accurately
represent
labeled
uses
in
all
cases.

d)
Occupational
Handler
Risk
Summary
(
1)
Seed
Treatment
Handler
Risk
Seeds
may
be
treated
with
PCNB
on
the
farm
or
at
a
commercial
seed
treatment
facility.
Seed
treatment
activities
that
may
result
in
exposure
are
loading/
applying
PCNB
to
seed;
bagging
treated
seed;
sewing
bags
of
treated
seed;
cleaning,
calibrating,
and
repairing
equipment;
operating
a
forklift;
and
planting
treated
seed.
The
Agency
was
able
to
estimate
exposures
for
a
subset
of
these
activities.
Individual
workers
may
perform
one
or
more
of
these
tasks
during
the
course
of
the
workday.
On­
farm
seed
treatment
represents
a
relatively
small
proportion
of
the
total
treated
seed
in
the
U.
S.
Workers
are
more
likely
to
perform
multiple
seed
treatment
tasks
when
seed
is
treated
on
the
farm
or
at
smaller
commercial
facilities.

Table
9
provides
short­
and
intermediate­
term
risk
estimates
for
seed
treatment
handlers
engaged
in
selected
activities,
wearing
baseline
attire
of
long
pants,
long
sleeved
shirts,
gloves,
and
no
respirator
and
using
open
systems.
All
registered
seed
uses
of
PCNB
were
assessed,
but
only
those
seed
types
with
MOEs
below
100
are
shown
below.
The
target
MOE
is
100,
so
MOEs
of
less
than
100
represent
risks
of
concern.
These
values
are
in
bold.
For
the
"
on­
farm"
treatment
activity,
seed
is
treated
in
and
planted
directly
from
the
planter
box.

Table
9.
Seed
Handler
Short
and
Intermediate­
Term
MOEs
by
Treatment
Activity
Loader/
applicator
Bagger
Multiple
activities
On­
Farm
Planters
Crop
D*
I
D
I
D
I
D
I
D
I
Barley
1000
200
2500
500
550
50
300
9000
3600
900
Pea
1500
350
4000
730
800
75
250
9000
13000
3000
Rice
900
200
2300
400
500
50
150
5300
2000
500
Soybean
1500
350
3900
700
800
75
3300
120000
7000
1600
*
D
=
dermal
MOE,
I
=
inhalation
MOE
Most
of
the
seed­
handler
exposure
scenarios
assessed
by
the
Agency
do
not
pose
risks
of
concern
for
seed
handlers
who
use
open
systems
for
loading
and
applying
PCNB
formulations,
and
who
wear
long
pants,
long
sleeved
shirts,
and
gloves,
but
no
respirators.
For
workers
­
19
­
­
engaging
in
multiple
seed
treatment
tasks
with
barley,
pea,
rice,
and
soybean,
MOEs
are
less
than
the
target
of
100
and
are
potentially
of
concern.
Since
these
risks
result
from
inhalation
exposures,
they
can
be
addressed
with
the
use
of
respirators.
The
Agency
believes
different
respirators
are
appropriate
for
different
tasks
(
e.
g.,
applying
PCNB
to
seed
vs.
operating
a
forklift
to
move
bags
of
treated
seed).
Specific
respirator
requirements
for
seed
handlers
are
detailed
in
Section
V
of
this
RED.

(
2)
Handler
Risks
for
Soil
and
Foliar
Uses
of
PCNB
The
Agency
assessed
over
100
scenarios
for
risks
to
occupational
handlers
associated
with
the
non­
seed
treatment
uses
of
PCNB.
These
handlers
may
be
exposed
while
mixing,
loading,
or
applying
PCNB
products
(
or
a
combination
of
these
activities),
and
during
flagging
for
aerial
applications.

The
risks
associated
with
these
scenarios
have
been
assessed
at
increasing
levels
of
protection
from
addition
of
personal
protective
equipment,
or
PPE
and
engineering
controls.
All
workers
are
assumed
to
be
wearing
baseline
attire
(
long­
sleeved
shirts,
long
pants,
socks
and
shoes
or
boots,
no
gloves,
and
no
respirator).
Additional
PPE
or
engineering
controls
added
to
the
baseline
for
the
different
levels
of
protection,
from
least
to
greatest
protection,
are:

°
PPE1
=
baseline
attire
plus
chemical
resistant
gloves
and
no
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
PPE2
=
baseline
attire
plus
chemical
resistant
gloves
and
a
dust/
mist
(
5­
fold
Protection
Factor,
or
PF)
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
PPE3
=
baseline
attire
plus
chemical
resistant
gloves
and
an
air
purifying
(
10­
fold
PF)
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
PPE4
=
coveralls
over
baseline
attire
plus
chemical
resistant
gloves
and
no
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
PPE5
=
coveralls
over
baseline
attire
plus
chemical
resistant
gloves
and
a
dust/
mist
(
5­
fold
PF)
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
PPE6
=
coveralls
over
baseline
attire
plus
chemical
resistant
gloves
and
an
air­
purifying
(
10­
fold
PF)
respirator
(
with
open
mixing
techniques
and
open
cab
tractors).

°
Engineering
Controls
=
baseline
attire
plus
chemical
resistant
gloves
and
no
respirator
with
closed
mixing
techniques
and
enclosed
cab
tractors
or
cockpits.

Additional
assumptions,
descriptions
of
scenarios,
and
data
sources
for
assessment
of
occupational
risk
may
be
found
in
Table
D1
of
the
November
15,
2004
document
"
Revised
Occupational
and
Residential
Exposure
Assessment
for
the
[
PCNB]
Reregistration
Eligibility
Decision
Document,"
which
has
been
posted
to
http://
www.
regulations.
gov/
in
Docket
Number
­
20
­
­
OPP­
2004­
0202
Tables
10­
14
show
short­
and
intermediate­
term
risk
estimates
for
non­
seed
treatment
occupational
handlers,
based
on
the
uses
of
PCNB
as
currently
registered,
for
scenarios
associated
with
risks
of
concern
at
any
level
of
protection.
(
The
full
complement
of
scenarios
and
associated
MOEs
may
be
found
in
Table
10
of
the
November
15,
2004
document).

MOEs
below
100
represent
risks
of
concern;
these
risks,
at
the
highest
level
of
protection
available
or
feasible,
are
shown
in
bold.
Scenarios
are
defined
by
handler
and
formulation
type,
method
of
application
and
application
equipment,
and
use
site.
For
scenarios
with
hand­
held
equipment,
engineering
controls
are
not
feasible
and
are
marked
N/
A.
Scenario
numbers
are
provided
for
ease
of
reference
to
the
November
15
document.

Table
10.
Short
and
Intermediate­
Term
Risk
for
Mixer/
Loaders
and
Loaders
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Mixer/
Loader,
or
for
Granular
Formulations,
Loader
Dry
Flowables;
Chemigation
(
6)
Sod
farms
28
28
39
N/
A
8
41
80
N/
A
Dry
Flowables;
Groundboom
(
9)
Soil
band
treatment
(
cole
crops)
130
130
190
N/
A
38
190
380
N/
A
Dry
Flowables;
Groundboom
(
11)
Peanuts
340
340
480
N/
A
98
500
980
N/
A
Liquids;
Groundboom
(
12)
Band
treatment
(
dried
beans,
succulent
beans,
lima)
45
5700
7700
15000
360
1800
3600
5300
Liquids;
Groundboom
(
13)
Band
treatment,
soil
treatment
(
garlic)
4.5
570
770
1500
36
180
360
530
Liquids;
Chemigation
(
14)
Ornamental
lawn
and
turf
44
5600
7600
15000
360
1800
3600
5200
Liquids;
Chemigation
(
15)
Commercial/
industrial
lawns
22
2800
3800
7500
180
890
1800
2600
Liquids;
Chemigation
(
16)
Sod
farms
0.63
80
110
210
5.1
26
51
74
Liquids;
Groundboom
(
16a)
Sod
farms
2.8
350
470
930
22
110
220
320
­
21
­
­
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Mixer/
Loader,
or
for
Granular
Formulations,
Loader
Liquids;
Chemigation
(
17)
Golf
course
turf
22
2800
3800
7500
180
890
1800
2600
Liquids;
Chemigation
(
18)
Golf
course
fairways
5.5
700
950
1900
45
220
450
650
Liquids;
High­
Pressure
HandWand
(
19)
Commercial/
industrial
lawn
48
6100
8200
16000
390
1900
3900
5600
Liquids;
Groundboom
(
20)
Cotton
18
2300
3100
6100
150
730
1500
2100
Liquids;
Groundboom
(
21)
Garlic
4.5
570
770
1500
36
180
360
530
Liquids;
Groundboom
(
22)
Peanuts
9.1
1100
1500
3100
73
360
730
1100
Liquids;
Groundboom
(
23)
Potato
3.6
460
620
1200
29
150
290
420
Liquids;
Chemigation
(
24)
Potato
0.83
100
140
280
6.7
33
67
96
Liquids;
Aerial
(
25)
Potato
0.83
100
140
280
6.7
33
67
96
Liquids;
Groundboom
(
26)
Soil
band
treatment
(
cole
crops)
3
380
510
1000
24
120
240
350
Liquids;
Airblast
(
28)
Foliar
spray
(
magnolia
tree)
60
7600
10000
20000
490
2400
4900
7000
Liquids;
Groundboom
(
29)
Tomato,
pepper
12
1500
2100
4100
97
490
970
1400
Liquids;
Groundboom
(
30)
Southern
pine
(
seed
orchard)
17
2100
2900
5700
140
690
1400
2000
Granulars;
Tractor­
Drawn
Spreaders
(
33)
Soil
band
treatment
(
cole
crops)
1000
1300
2600
51000
17
86
170
860
Granulars;
Tractor­
Drawn
Spreaders
(
34)
Golf
course
turf
(
tees,
greens)
5700
7000
14000
280000
95
470
950
4700
Granulars;
Tractor­
Drawn
Spreaders
(
35)
Golf
course
turf
(
fairways)
1400
1700
3500
71000
24
120
240
1200
­
22
­
­
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Mixer/
Loader,
or
for
Granular
Formulations,
Loader
Granulars;
Tractor­
Drawn
Spreaders
(
36)
Sod
farms
720
870
1800
35000
12
59
120
590
Granulars;
Tractor­
Drawn
Spreaders
(
39)
Potato
1300
1500
3100
62000
21
100
210
1000
Wettable
Powders;
Groundboom
(
40)
beans
(
lima,
snap,
dried)
47
1000
1300
18000
14
68
140
2400
Wettable
Powders;
Chemigation
(
41)
beans(
lima,
snap,
dried)
11
240
310
4100
3.1
16
31
560
Wettable
Powders;
Chemigation
(
42)
soil
band
treatment
(
cole
crops)
0.54
12
15
200
0.16
0.78
1.6
28
Wettable
Powders;
Groundboom
(
43)
soil
band
treatment
(
cole
crops)
2.4
51
67
890
0.68
3.4
6.8
120
Wettable
Powders;
Chemigation
(
44)
commercial/
industrial
lawns
14
300
400
5300
4
20
40
710
Wettable
Powders;
High­
Pressure
HandWand
(
45)
commercial/
industrial
lawns
11
250
320
4300
3.3
16
33
580
Wettable
Powders;
Groundboom
(
46)
cotton
14
310
400
5400
4.1
20
41
730
Wettable
Powders;
Chemigation
(
47)
cotton
8.1
180
230
3100
2.3
12
23
420
Wettable
Powders;
Chemigation
(
48)
golf
course
tees,
greens
14
300
400
5300
4
20
40
710
Wettable
Powders;
Chemigation
(
49)
golf
course
fairways
3.5
76
99
1300
0.100
5
1.00
180
Wettable
Powders;
Chemigation
(
50)
sod
farms
0.4
8.7
11
150
0.11
0.57
1.1
20
Wettable
Powders;
Groundboom
(
51)
sod
farms
1.7
38
49
660
0.50
2.5
5
89
Wettable
Powders;
Groundboom
(
52)
peanuts
35
770
1000
13000
10
51
100
1800
Wettable
Powders;
Chemigation
(
53)
peanuts
8.1
180
230
3100
2.3
12
23
420
­
23
­
­
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Mixer/
Loader,
or
for
Granular
Formulations,
Loader
Wettable
Powders;
Groundboom
(
54)
pepper,
tomato
9.5
210
270
3600
2.7
14
27
490
Wettable
Powders;
Groundboom
(
55)
pine
(
seed
orchard)
15
330
430
5700
4.3
22
43
780
*
N/
A
=
data
not
available
Table
11.
Short
and
Intermediate­
Term
Risk
for
PCNB
for
Applicators
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Eng.
Controls
Applicator
Dry
Flowables;
Sprays;
High­
Pressure
HandWand
(
57)
commercial/
industrial,
residential
lawns
310
880
1600
N/
A
24
120
240
N/
A
Dry
Flowables;
Sprays;
High­
Pressure
HandWand
(
58)
ornamentals
(
foliar
application
only)
7.8
22
39
N/
A
0.59
2.9
5.9
N/
A
Dry
Flowables;
Sprays;
Groundboom
(
60)
Soil
band
treatment
(
cole
crops)
630
630
800
1800
39
190
390
680
Emulsifiable
Concentrates;
Sprays;
Groundboom
(
64)
Band
treatment,
(
garlic)
940
940
1200
2600
59
290
590
1000
Emulsifiable
Concentrates;
Sprays;
High­
Pressure
HandWand
(
65)
Commercial/
industrial
lawn
78
220
390
N/
A
5.9
29
59
N/
A
Emulsifiable
Concentrates
;
Sprays;
Groundboom
(
67)
Garlic
940
940
1200
2600
59
290
590
1000
Emulsifiable
Concentrates;
Sprays;
Groundboom
(
69)
Potato
750
750
950
2100
47
230
470
810
Emulsifiable
Concentrates;
Sprays;
Groundboom
(
71)
Soil
band
treatment
(
cole
crops)
630
630
800
1800
39
190
390
680
Emulsifiable
Concentrates;
Sprays;
High­
Pressure
HandWand
(
72)
container
stock
(
cole
crops)
780
2200
3900
N/
A
59
290
590
N/
A
­
24
­
­
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Eng.
Controls
Applicator
Granulars;
Tractor­
Drawn
Spreaders
(
77)
Soil
band
treatment
(
cole
crops)
880
1200
2100
4200
24
120
240
130
Granulars;
Tractor­
Drawn
Spreaders
(
79)
Golf
course
turf
(
fairways)
1200
1700
2900
5700
33
170
330
180
Granulars;
Tractor­
Drawn
Spreaders
(
80)
Sod
farms
610
840
1400
2900
17
84
170
91
Granulars;
Tractor­
Drawn
Spreaders
(
84)
Potato
1100
1500
2500
5000
29
150
290
160
Wettable
Powders;
Sprays;
Groundboom
(
86)
Soil
band
treatment
(
cole
crops)
630
630
800
1800
39
190
390
680
Wettable
Powders;
Sprays;
High­
Pressure
HandWand
(
87)
commercial/
industrial
lawns
23
66
120
N/
A
1.8
8.8
18
N/
A
Wettable
Powders;
Sprays;
Groundboom
(
89)
Sod
farms
460
460
580
1300
29
140
290
500
Wettable
Powders;
Sprays;
Groundboom
(
89a)
Sod
farms
570
570
730
1600
36
180
360
620
Table
12.
Short
and
Intermediate­
Term
Risk
for
PCNB
for
Flaggers
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Flagger
Aerial
Spray
s
(
93)
Potato
220
240
240
11000
23
110
230
1100
Table
13.
Short
and
Intermediate­
Term
Risk
for
PCNB
for
Mixer/
Loader/
Applicators
or
Loader/
Applicators
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Mixer/
Loader/
Applicator,
or;
Granulars,
Loader/
Applicator
­
25
­
­
Dermal
MOE
Inhalation
MOE
Exposure
Scenario
(#)
Use
Site
Baseline
PPE1
PPE2
PPE3
PPE4
PPE5
PPE6
Engineering
Controls
Baseline
PPE1
PPE4
PPE2
PPE5
PPE3
PPE6
Engineering
Controls
Liquids;
Handgun
Sprayer
(
94)
Ornamental
herbaceous
plants,
woody
shrubs,
vines
Data
not
available
77
N/
A
36
Data
not
available
N/
A
Granulars;
Push­
type
spreader
(
96)
Commercial/
industrial
lawns
280
440
880
N/
A
44
Data
not
available
N/
A
Granulars;
Belly
Grinder
(
97)
Ornamental
lawns
and
turf
96
100
No
data
N/
A
52
270
520
N/
A
Granulars;
Belly
Grinder
(
98)
Ornamental
shade
trees,
herbaceous,
woody
shrubs,
vines
19
21
No
data
N/
A
10
54
100
N/
A
Granulars;
Push­
type
spreader
(
99)
Ornamental
shade
trees,
herbaceous,
woody
shrubs,
vines
550
880
1800
N/
A
88
Data
not
available
N/
A
Wettable
Powders;
Low
Pressure
Handwand
(
100)
Ornamental
woody
shrubs,
vines,
herbaceous
plants
2.2
2.2
3.1
N/
A
0.058
0.29
0.58
N/
A
Wettable
Powders;
Low
Pressure
Handwand
(
101)
Ornamental
shade
trees
13
13
18
N/
A
0.34
1.7
3.4
N/
A
For
many
scenarios
with
risks
of
concern
at
lower
levels
of
protection,
the
addition
of
PPE
or
engineering
controls
can
increase
MOEs
above
100.
For
applications
with
hand­
held
equipment,
the
use
of
engineering
controls
is
not
feasible.
For
some
scenarios,
there
are
no
feasible
protective
measures
that
will
increase
MOEs
above
100.
MOEs
less
than
100
at
the
highest
level
of
protection
assessed
or
feasible
are
in
bold.

e)
Occupational
Post­
application
Risks
In
general,
there
is
a
low
potential
for
occupational
post­
application
exposure
when
a
preplant
or
at­
plant
fungicide
is
used.
Significant
exposure
during
harvesting
or
other
late
season
activities
is
not
likely
for
a
pesticide
applied
at
this
time.
The
Agency
has
not
assessed
postapplication
risk
for
seed
treatments
or
at­
plant
uses
of
PCNB.
Applications
of
PCNB
may
be
­
26
­
­
made
to
turf
at
any
time
during
the
growing
season,
and
into
winter
in
some
areas.
There
are
potential
post­
application
exposures
for
workers
re­
entering
PCNB­
treated
turf
for
mowing
and
other
maintenance
activities.
The
Agency
believes
that
these
scenarios
represent
the
highest
potential
occupational
post­
application
exposures
for
PCNB.
The
Agency
typically
estimates
risk
to
workers
on
the
day
of
treatment
(
day
0),
and
if
MOEs
are
below
100,
will
estimate
risk
for
subsequent
days
until
the
MOEs
exceed
100.
In
the
case
of
PCNB,
the
assessment
yields
MOEs
above
the
threshold
on
day
0.
MOEs
were
estimated
for
two
application
rates.
These
estimates
are
shown
in
Table
14.

Chemical
specific
post­
application
exposure
data
have
not
been
submitted
in
support
of
the
reregistration
of
PCNB.
Details
on
the
studies
used
as
the
basis
for
estimating
postapplication
risk
associated
with
PCNB
and
the
approach
the
Agency
took
to
assess
those
risks
may
be
found
in
the
document
"
Revised
Occupational
and
Residential
Exposure
Assessment
for
the
[
PCNB]
Reregistration
Eligibility
Decision
Document,
November
15,
2004."

Table
14.
Occupational
Post­
application
Risks
at
Day
Zero
Use
Site
Application
Rate
(
lb
ai/
acre)
Activities
MOE
Golf
Course
Turf
32.67­
43.56
Mow,
seed,
weed
(
mechanically),
aerate,
fertilize,
prune
2100­
1580
Sod
Farms
32.67­
43.56
Mow,
scout,
weed
(
mechanically),
irrigate
1120­
790
At
day
zero,
all
MOEs
are
above
the
target
of
100.
The
Agency
believes
that
other
postapplication
occupational
scenarios
are
also
likely
to
yield
MOEs
greater
than
100.

7.
Human
Incident
Data
According
to
the
Recognition
and
Management
of
Pesticide
Poisoning,
5th
Edition,
symptoms
of
prolonged
exposure
to
PCNB
can
include
skin
sensitization
and
irritation,
and
following
eye
contact,
conjunctivitis
and
keratitis.
Systemic
poisoning
has
not
been
reported.
Clearance
is
chiefly
via
the
liver
and
biliary
excretion.

According
to
the
American
Association
of
Poison
Control
Centers,
between
1993
and
1998,
41
cases
of
PCNB
exposure
were
reported.
There
were
21
symptomatic
cases,
including
six
ranked
moderate.
Fifteen
of
the
individuals
reported
in
the
41
cases
were
seen
in
a
health
care
facility,
and
one
was
hospitalized.

The
California
Pesticide
Illness
Surveillance
Program
reported
30
PCNB
incidents
from
1982­
1997,
most
involving
PCNB
in
mixtures
with
other
pesticides.
Of
the
seven
case
reports
for
PCNB
alone,
most
were
older
cases
related
to
eye
contamination.
­
27
­
­
Between
1984
and
1991,
the
National
Pesticides
Telecommunications
Network
reported
16
human
incidents
and
five
animal
incidents
associated
with
PCNB.

These
numbers
are
relatively
small
compared
to
other
pesticides
for
which
incidents
have
been
reported
and
are
consistent
with
the
low
acute
toxicity
of
PCNB.

B.
Environmental
Risk
Assessment
The
basis
for
this
summary
of
the
environmental
risk
assessment
for
PCNB
is
the
document
entitled
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,"
February
12,
2005.
The
complete
assessment
has
been
posted
to
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

1.
Fate
and
Transport
Based
on
the
submitted
environmental
fate
data,
physical­
chemical
properties,
use
patterns,
and
information
found
in
the
published
literature,
PCNB
is,
in
general,
expected
to
be
a
persistent,
moderately
volatile
compound
that
will
be
immobile
in
most
soils,
but
may
have
slight
or
even
moderate
mobility
in
coarser
(
sandy)
soils,
particularly
those
that
are
low
in
organic
matter.
Table
15
summarizes
the
physical­
chemical
properties
of
PCNB,
a
relatively
high
molecular
weight
compound
with
low
water
solubility.

Table
15.
Fate
and
Physical­
Chemical
Properties
of
PCNB
Parameter
Value
Molecular
Weight
295.3g
Solubility
(
25
oC)
0.44
mg/
L
(
440
ppb)

Vapor
Pressure
(
25
oC)
1.13
x
10­
4
mmHg
Hydrolysis
Half­
life
(
pH
5,
7,
9;
25
oC)
stable
Aqueous
Photolysis
Half­
lives
(
pH
5)
2.5
days
26.8
hours
Soil
Photolysis
Half­
life
stable
Aerobic
Soil
Metabolism
Half­
lives
77,
189
days
(
measured,
parent
only);
Calculated
values:
489,
1012
days
(
parent
plus
PCA)
983,
1052
days
(
total
residues)

Anaerobic
Soil
Metabolism
Half­
lives
9
days,
<
30
days
(
DT50;
parent
only);
410
days
(
parent
plus
PCA)
334
days
(
total
residues)

Organic
Carbon
Partition
Coefficients
(
Koc)
1588­
17508
­
28
­
­
Parameter
Value
Soil
Partition
Coefficients
(
Kd,
mL/
g)
7.3,
15.5,
19.1,
210
Bioconcentration
Factors
(
BCF)
in
fish
(
bluegill
sunfish)
370­
400
edible
tissue
1800
viscera
960­
1100
whole
fish
tissue
a)
Metabolites
PCNB
has
over
80
metabolites,
or
degradates.
The
major
degradates
of
PCNB
in
the
environment
are
PCA,
PCTA,
and
pentachlorobenzene
(
also
present
as
an
impurity);
minor
degradates
are
pentachlorothioanisole
sulfoxide
(
PCTASO),
and
pentachlorothioanisole
sulfone
(
PCTASO2).
PCNB
also
contains
the
manufacturing
contaminant
hexachlorobenzene
(
HCB),
which
also
has
been
reported
as
a
degradate
in
registrant­
submitted
field
dissipation
and
anaerobic
aquatic
metabolism
studies.
Pentachlorophenol,
which
is
also
a
pesticide
active
ingredient
and
a
probable
carcinogen,
also
was
detected
as
a
metabolite
of
PCNB
in
several
registrant­
submitted
studies
but
the
conditions
which
favor
its
formation
have
not
been
identified.
Structures
of
the
parent
compound
and
its
degradates
are
presented
in
APPENDIX
C
of
the
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,
February
12,
2005."

For
the
drinking
water
and
ecological
risk
assessments,
degradation
half­
lives
in
water
were
calculated
using
parent
data
plus
data
for
degradates
in
soil.
To
determine
the
half­
lives,
the
concentrations
of
the
parent
and
appropriate
degradate(
s)
were
summed,
and
half­
lives
were
calculated
using
first­
order
linear
regression;
degradation
kinetics
for
the
parent
and
the
various
degradates
were
not
determined
separately
and
then
combined.
This
approach
is
conservative,
but
should
not
overestimate
the
half­
lives
relative
to
such
estimates
determined
using
individual
kinetic
rates
for
each
compound.
Volatiles
were
included
when
half­
lives
were
recalculated
For
use
in
the
drinking
water
assessment,
half­
lives
were
recalculated
for
the
parent
compound
plus
the
degradate
PCA.
Half­
lives
were
recalculated
for
total
residues
(
represented
by
PCNB,
PCA,
PCTA,
pentachlorobenzene,
pentachlorophenol,
PCTASO,
PCTASO2
and
HCB)
for
use
in
the
environmental
assessment.

b)
Field
Dissipation
In
terrestrial
field
dissipation
studies,
PCNB
dissipated
more
rapidly
when
the
pesticide
was
not
incorporated.
Major
degradates
in
these
studies
included
PCA,
PCTA
and
pentachlorobenzene.
Although
pentachlorobenzene
is
present
as
a
manufacturing
impurity
in
PCNB,
increases
in
its
concentration
over
time
confirmed
that
it
was
formed
as
a
degradate
of
PCNB
in
the
field.
In
a
study
of
field
soils
cropped
with
potatoes
and
to
which
PCNB
had
been
applied
over
the
previous
five
to
11
years,
field
half­
lives
were
as
long
as
1059
days.

c)
Volatility
­
29
­
­
PCNB
and
many
of
its
metabolites
are
moderately
volatile.
Volatilization
is
likely
a
significant
route
of
dissipation
when
the
pesticide
is
not
incorporated,
as
when
it
is
applied
as
a
foliar
spray
(
e.
g.,
to
turf)
or
through
overhead
sprinkler
irrigation;
e.
g.,
chemigation
on
potatoes).
PCNB
may
volatilize
more
from
moist
or
saturated
soils
than
dry
soils
because
it
adsorbs
less
to
wetter
soils.
One
study
reports
that
most
of
the
PCNB
that
was
lost
from
soil
during
10
months
of
incubation
was
due
to
volatilization.

d)
Photodegradation
The
primary
degradation
pathway
for
PCNB
in
clear
and
shallow
surface
water
is
through
photodegradation,
when
the
compound
is
present
in
an
unsorbed
state.
Photodegradation
of
PCNB
in
surface
water
is
moderately
rapid,
with
half­
lives
on
the
order
of
a
few
days
or
less.
Photodegradation
of
PCNB
in
turbid
or
deeper
waters
may
be
limited
by
the
attenuation
of
sunlight
and
adsorption
of
the
compound
to
suspended
particles
in
the
water
column.
PCNB
is
stable
to
hydrolysis,
and
stable
to
photodegradation
on
soil.

e)
Aerobic
and
Anaerobic
Metabolism
As
seen
in
Table
15,
PCNB
biodegrades
slowly
in
aerobic
soils
and
more
rapidly
in
anaerobic
soils.
The
persistence
of
PCNB
in
aerobic
soils
is
supported
by
data
in
the
published
literature,
with
half­
lives
of
almost
10
months
reported
in
one
citation.
Guideline
aquatic
metabolism
data
for
PCNB
have
not
been
submitted.

f)
Mobility
PCNB
is
immobile
in
most
soils,
but
may
have
slight
or
even
moderate
mobility
in
soils
low
in
organic
matter.
PCNB
has
a
low
potential
for
leaching
to
groundwater.
PCA
and
PCTA
are
expected
to
be
immobile
in
soil.
Pentachlorobenzene
is
slightly
mobile
to
immobile
in
soil.
In
terrestrial
field
dissipation
studies,
PCNB
generally
did
not
leach
below
the
6­
to
12­
inch
soil
depth,
and
PCA,
PCTA
and
pentachlorobenzene
generally
remained
in
the
0­
to
6­
inch
soil
depth.
g)
Drift
and
Surface
Water
PCNB
may
reach
surface
water
through
drift
when
applied
as
a
spray
and
particularly
with
foliar
applications
(
such
as
to
turf).
PCNB
and
its
major
degradates
are
all
generally
persistent
under
field
conditions
and
may
reach
surface
water
bodies.
The
slow
biodegradation
of
PCNB
in
most
soils
will
increase
opportunities
for
surface
water
contamination.

h)
Bioconcentration
PCNB
has
a
very
high
potential
to
bioaccumulate
in
fish.
Fish
will
metabolize
PCNB,
but
the
impact
of
depuration
is
limited
by
the
persistence
of
PCNB
and
its
metabolites
in
the
aquatic
environment,
which
create
a
regular
source
of
exposure.
Bioconcentration
factors
(
BCFs)
are
reported
in
other
fish
species
at
levels
consistent
with
those
reported
for
bluegill
sunfish,
i.
e.,
up
to
1100X
in
whole
fish.
Higher
BCF
values
have
been
reported
for
aquatic
plants,
at
up
to
3100X
for
algae.
­
30
­
­
2.
Impact
of
Fate
Characteristics
on
Risk
The
Agency
is
particularly
concerned
about
PCNB's
environmental
persistence,
bioaccumulative
potential,
and
potential
for
long­
range
transport.
These
fate
characteristics
increase
the
extent
and
scope
of
the
risks
PCNB
and
its
metabolites
pose
to
nontarget
organisms,
but
their
effect
cannot
be
quantified.

The
relationship
between
PCNB's
fate
characteristics
and
ecological
risk
is
detailed
in
the
document
"
Synopsis
of
Pentachloronitrobenzene
Environmental
Loading
and
Ecological
Risk,"
April
26,
2006,
which
is
accessible
through
http://
www.
regulations.
gov/
,
Docket
Number
OPP­
2004­
0202.
To
summarize
this
relationship:

The
persistence
of
PCNB
and
its
metabolites
in
the
environment:
°
increases
opportunities
for
exposure
because
organisms
are
exposed
to
residues
for
a
long
time
after
application
of
the
pesticide
(
or
may
be
continuously
exposed
between
applications)
°
limits
the
extent
of
depuration
because
organisms
remain
in
contact
with
or
may
ingest
food
items
contaminated
with
residues
°
increases
opportunities
for
bioaccumulation
through
the
food
chain
The
evidence
that
PCNB
and
is
metabolites
are
subject
to
long­
range
transport
is
limited
but
compelling,
and:
°
field
data
show
significant
quantities
of
PCNB
can
volatilize
from
the
field
°
exposure
models
do
not
account
for
long­
range
transport
and
underestimate
exposure;
°
PCNB
is
not
expected
to
degrade
appreciably
in
the
atmosphere
°
atmospheric
transport
increases
opportunities
for
exposure
and
increases
the
extent
of
risk
(
exposure
occurs
outside
areas
where
PCNB
is
applied
and
to
species
which
otherwise
would
not
be
exposed)

PCNB
and
its
metabolites
partition
to
organic
matter
and
sediment,
and:
°
effects
on
benthic
organisms
are
uncertain
and
unaccounted
for
in
the
risk
assessment
°
this
partitioning
likely
contributes
to
bioaccumulation
and
amplification
of
residues
in
the
food
chain
The
fate
characteristics
of
PCNB
and
its
metabolites
(
including
persistence
and
partitioning
to
lipids
and
organic
matter)
indicate
the
potential
to
bioaccumulate
up
the
food
chain.
While
bioconcentration
data
are
limited:
°
application
of
the
Gobas
food
web
bioaccumulation
model
developed
by
EPA's
Office
of
Water
(
http://
www.
epa.
gov/
glnpo/
lmmb/
foodweb.
html)
suggests
that
the
aquatic
food
chain
can
serve
as
a
mechanism
for
significant
bioaccumulation
°
the
risk
quotients
cited
in
this
RED
do
not
account
for
exposures
related
to
bioaccumulation,
so
they
understate
ecological
risks
­
31
­
­
In
addition,
the
metabolites
of
PCNB
are
not
only
likely
to
be
persistent
and
have
the
potential
to
bioaccumulate:
°
they
are
assumed
to
be
toxicologically
equivalent
to
PCNB
°
and
are
accounted
for
in
modeling
the
aquatic
exposures
cited
in
this
RED,
but
not
in
the
terrestrial
exposures,
resulting
in
underestimates
of
risk
3.
Environmental
Loading
The
combined
effect
of
the
fate
characteristics
on
the
amount
of
the
pesticide
and
its
metabolites
entering
and
remaining
in
the
environment
is
referred
to
in
this
document
as
"
environmental
loading."
Environmental
loading
varies
with
the
different
use
sites
for
a
pesticide,
and
is
a
function
of
how
much
of
the
pesticide
is
introduced
into
the
environment,
as
measured
by
usage
(
pounds
applied
for
a
use
site
on
an
annual
basis),
percent
crop
treated
(
what
proportion
of
a
given
use
site
is
treated
in
a
year),
application
rates,
and
application
methods
(
for
a
volatile
pesticide
like
PCNB,
a
foliar
application
may
result
in
more
volatilization
and
a
greater
potential
for
long­
range
transport).

PCNB
is
a
widely
used
pesticide
with
many
different
use
sites.
These
use
sites
differ
in
usage,
percent
crop
treated,
application
rate,
and
application
method.
The
fate
characteristics
of
PCNB
and
its
metabolites
tend
to
increase
the
amount
of
these
compounds
that
remain
biologically
available
in
the
environment,
for
long
periods
after
application.
There
is
a
great
deal
of
evidence
to
indicate
that
toxic
residues
of
PCNB
will
persist
in
the
environment
and
that
the
aquatic
community
is
particularly
vulnerable
to
this
chemical.
Based
on
the
screening
level
assessment
summarized
in
this
RED,
estimated
environmental
concentrations
are
sufficient
to
result
in
both
acute
and
chronic
effects
on
aquatic
animals.
It
likely
that
if
the
full
effect
of
the
persistence,
bioconcentration,
and
long­
range
transport
characteristics
of
PCNB
and
its
metabolites
associated
with
environmental
loading
could
be
quantified,
aquatic
organisms
could
be
exposed
to
PCNB
residues
that
exceed
acute
and
chronic
effect
thresholds
by
several
orders
of
magnitude.
The
fate
and
toxicological
characteristics
of
PCNB
and
its
metabolites
are
not
fully
quantified
in
this
RED
and
contribute
to
an
underestimation
of
risk.

4.
International
and
Domestic
Standards
for
Persistence,
Bioaccumlation,
and
Long­
range
Transport
The
persistence,
bioaccumulative
potential,
potential
for
long­
range
transport
,
and
ecotoxicity
of
PCNB
and
its
metabolites,
when
examined
relative
to
national
and
international
standards,
suggest
that
PCNB
has
much
in
common
with
substances
that
have
been
officially
identified
as
"
persistent
organic
pollutants"
(
POPs)"
and
"
persistent
bioaccumulative
toxic
substances"
(
PBTs).

The
2001
Stockholm
Convention
establishes
global
controls
on
substances
listed
as
POPs,
defining
them
as
organic
substances
that
are
persistent
and
bioaccumulate,
have
potential
for
longrange
transport,
and
are
likely
to
cause
significant
adverse
human
health
or
environmental
effects.
PCNB
is
not
one
of
the
12
POPs
listed
for
elimination
or
restriction,
nor
is
the
Agency
proposing
­
32
­
­
that
PCNB
be
listed
as
a
POP,
but
the
Agency
believes
that
PCNB
shares
some
characteristics
with
substances
which
may
be
proposed
for
listing.

Screening
criteria
have
been
established
to
identify
compounds
which
may
be
added
to
the
original
POPs
list.
The
screening
criteria
are
described
in
Annex
D
of
the
Convention,
which
can
be
found
at
http://
www.
pops.
int/
documents/
convtext/
convtext_
en.
pdf.
The
screening
criteria
and
how
PCNB
relates
to
these
criteria
are
described
below.

a)
Persistence
The
POPs
criterion
for
persistence
is
a
half­
life
in
water
greater
than
two
months,
soil
and
sediment
half­
lives
greater
than
six
months
or,
alternatively,
evidence
that
the
substance
is
otherwise
sufficiently
persistent
to
be
of
concern.

No
data
are
available
for
PCNB
half­
lives
in
water.
The
half­
life
of
PCNB
alone
in
aerobic
soil
has
been
measured
as
189
days;
for
the
parent
plus
PCA
half­
lives
are
489
and
1012
days
(
two
studies,
results
supported
by
the
open
literature).
The
anaerobic
soil
half­
life
for
PCNB
plus
PCA
is
410
days.
Residues
of
PCNB
and
its
metabolites
remain
in
soil
and
may
be
taken
up
by
plants
in
measurable
quantities
several
years
after
PCNB
was
last
applied.
PCNB
clearly
meets
the
persistence
criterion.

b)
Bioaccumulation
The
POPs
criterion
for
bioaccumulation
is
a
bioaccumulation
or
bioconcentration
factor
greater
than
5,000
in
aquatic
species;
a
log
octanol­
water
coefficient
(
Kow)
greater
than
5;
evidence
that
a
chemical
presents
other
reasons
for
concern,
such
as
high
bioaccumulation
in
other
species,
high
toxicity
or
ecotoxicity;
or
monitoring
data
indicating
the
bioaccumulation
potential
of
the
chemical
is
sufficient
to
warrant
its
consideration.

Bioaccumulation
is
the
net
uptake
of
a
chemical
from
the
environment
by
all
possible
routes
(
respiration,
diet,
dermal)
from
any
source
(
water,
dissolved,
colloidal
or
particular
organic
carbon,
sediment
and
other
organisms)
(
Spacie
et
al.
1995).
Bioconcentration
is
a
measure
of
the
relative
amounts
of
residues
in
tissue
to
concentrations
in
water.

PCNB
has
a
tendency
to
bioconcentrate
in
aquatic
organisms.
Bioconcentration
factors
(
BCFs)
of
1100
and
1800X
have
been
reported
for
whole
fish
and
visceral
tissue
respectively.
BCFs
as
high
as
3100X
have
been
observed
for
PCNB
in
aquatic
plants.
The
log
Kow
for
PCNB
is
reported
as
4.22
(
Hansch
et
al.,
1995).
PCNB
does
not
meet
the
bioconcentration
criterion
on
the
basis
of
either
BCFs
or
log
Kow.

Empirical
information
on
bioaccumulation
for
PCNB
is
lacking,
but
its
fate
characteristics,
and
the
fate
characteristics
of
its
metabolites,
suggest
a
tendency
to
bioaccumulate
up
the
food
chain,
based
on
their
tendency
to
concentrate
in
organic
matter,
sediment,
and
lipids.
In
addition,
the
ecotoxicity
and
fate
characteristics
of
PCNB
contribute
to
opportunities
for
non­
target
exposures,
and
potential
risks
of
concern,
in
a
broad
range
of
species
and
both
within
and
outside
­
33
­
­
areas
where
PCNB
is
applied.
Although
it
is
not
clear
that
PCNB
meets
the
POPs
numerical
criteria
for
bioaccumulation,
its
ecotoxicity
and
fate
characteristics
suggest
other
reasons
for
concern
about
its
bioaccumulative
potential.

c)
Long­
range
Transport
The
POPs
criterion
for
long­
range
environmental
transport
is
detection
of
the
chemical
in
locations
distant
from
the
source;
monitoring
data
showing
that
long­
range
transport
may
occur
via
air,
water
or
migratory
species;
environmental
fate
properties
demonstrating
potential
for
long­
range
transport;
and,
for
a
chemical
that
migrates
through
air,
a
half­
life
in
air
of
greater
than
two
days
Residues
of
PCNB
have
been
detected
in
locations,
e.
g.,
Saskatchewan,
Canada,
where
it
is
not
used.
Based
on
its
vapor
pressure,
PCNB
will
exist
almost
exclusively
in
the
vapor
phase
in
the
atmosphere.
The
estimated
photo­
oxidation
half­
life
for
PCNB
in
the
vapor
phase
is
estimated
to
be
2,200
days.
Given
that
the
compound
is
also
hydrolytically
stable,
degradation
in
the
atmosphere
is
expected
to
be
negligible.
PCNB
meets
the
long­
range
transport
criterion.

d)
Adverse
Effects
The
POPs
criterion
for
adverse
effects
is
toxicity
or
ecotoxicity
data
that
indicate
the
potential
for
damage
to
human
health
or
to
the
environment.

PCNB
is
toxic
in
many
test
species,
including
those
representing
wildlife.
PCNB
is
highly
toxic
to
freshwater
fish
and
invertebrates
(
LC50s
between
0.1
and
1.0
mg/
L)
and
very
highly
toxic
to
estuarine/
marine
fish
and
invertebrates
(
LC50
less
than
0.1
mg/
L)
on
an
acute
exposure
basis.
PCNB
is
toxic
on
chronic
basis
to
aquatic
and
terrestrial
animals.
PCNB
meets
the
adverse
effects
criterion
established
by
the
Stockholm
Convention.

A
contaminant
and
metabolite
of
PCNB,
pentachlorobenzene,
has
been
nominated
for
addition
to
the
Convention
on
Long­
range
Transboundary
Air
Pollution
(
LRTAP),
a
regional
agreement
on
air
pollutants
similar
to
the
global
POPs
Convention.

e)
PBT
Criteria
and
the
Resource
Conservation
Challeng
The
Agency
has
also
established
criteria
for
identifying
Persistent
Bioaccumulative
Toxic
substances
(
PBTs).
Criteria
are
defined
at
two
levels,
the
more
restrictive
of
which
calls
for
a
ban
on
production
while
additional
data
are
developed.
The
criteria
can
be
found
at:
http://
www.
epa.
gov/
fedrgstr/
EPA­
TOX/
1999/
November/
Day­
04/
t28888.
htm.

The
more
restrictive
criterion
for
persistence
is
a
half­
life
in
soil
of
60
days
or
more.
PCNB
alone
and
PCNB
plus
its
predominant
metabolite,
PCA,
exceed
this
criterion.
PCNB
exceeds
the
less
restrictive
bioconcentration
criterion
of
a
BCF
greater
than
1000.
According
to
PBT
criteria,
determinations
of
toxicity
are
based
on
best
professional
judgment
on
existing
data.
As
noted
above,
PCNB
is
very
toxic
to
a
wide
range
of
fauna.
­
34
­
­
The
PBT
criteria,
which
are
the
basis
for
regulatory
action
relating
to
pre­
manufacture
notices
for
toxic
substances,
excluding
pesticides,
have
also
been
used
by
the
Agency
to
identify
priority
chemicals
for
the
Resource
Conservation
Challenge
(
RCC).
Under
the
RCC,
PCNB
has
been
identified
as
one
of
31
priority
chemicals
for
which
a
strategy
is
being
developed
for
voluntary
reduction
in
waste
streams,
through
a
variety
of
programs
including
pollution
prevention,
substitution,
minimization,
and
cradle­
to­
grave
chemical
management.
Documentation
may
be
found
at
http://
www.
epa.
gov/
epaoswer/
hazwaste/
minimize/
chemlist.
htm
and
http://
www.
epa.
gov/
epaoswer/
osw/
conserve/
strat
plan/
strat
plan.
htm#
chemreduc.

5.
Monitoring
Data
There
are
no
surface
water
monitoring
data
available
for
PCNB
or
PCA
in
the
US
Geological
Survey's
National
Water
Quality
(
NAWQA)
database
(
neither
of
the
compounds
is
an
analyte).
According
to
EPA's
Pesticides
in
Ground
Water
Database,
A
Compilation
of
Monitoring
Studies:
1971­
1991,
National
Summary,
PCNB
is
not
found
in
groundwater
at
significant
levels
or
frequencies.
In
sampling
of
1708
wells,
only
three
detections
of
PCNB
occurred,
at
a
range
of
0.008
to
0.275
µ
g/
L.
No
information
is
available
on
whether
the
monitoring
sites
corresponded
with
PCNB
use
sites
or
times
of
usage.

In
a
groundwater
monitoring
study
of
18
wells
in
three
counties
in
California
(
July
1994 
1995),
PCNB
was
not
detected
(
California
EPA,
1995).
In
a
review
of
multiple
studies
in
which
sampling
was
conducted
in
surface
water
and/
or
groundwater
at
golf
courses,
PCNB
was
monitored
in
surface
water
for
an
unspecified
number
of
studies,
but
was
not
detected
(
Cohen
et
al.,
1999).

A
literature
search
was
conducted
to
obtain
published
information
(
generally
post­
1990)
on
the
occurrence
of
PCNB
and
its
degradates
in
the
aquatic
and
terrestrial
environments.
PCNB,
PCA,
and
PCTA
have
not
been
detected
frequently
in
North
American
waters.
Detections
of
pentachlorophenol
in
the
environment
cannot
necessarily
be
attributed
to
the
degradation
of
PCNB,
as
pentachlorophenol
itself
is
extensively
used
as
a
wood
preservative.
Similarly,
detections
of
pentachlorobenzene
are
probably
most
commonly
the
result
of
its
formation
as
a
byproduct
in
the
manufacture
of
other
compounds
or
as
a
degradate
of
hexachlorobenzene
(
HCB),
and
industrial
uses.

The
compounds
PCA,
pentachlorobenzene,
and
PCP
were
monitored
in
studies
of
the
Mississippi
River
and
tributaries
(
Illinois,
Missouri,
Ohio,
Arkansas,
White,
and
Yazoo
Rivers;
Rostad
et
al.,
1993).
PCA
was
detected
in
the
surface
waters
at
multiple
locations,
at
concentrations
of
0.018
to
0.055
ng/
L.
Pentachlorobenzene
was
detected
in
the
Mississippi
River
and
two
of
its
main
tributaries,
but
was
not
likely
a
result
of
PCNB
use.
Its
presence
was
attributed
to
degradation
of
HCB,
as
suggested
by
the
concentration
profiles
of
the
two
compounds.
PCP
was
not
found
in
any
of
the
surface
water
samples.

The
Agency
has
concluded
that
monitoring
data
on
PCNB
are
limited
and/
or
incomplete
information
is
available.
As
such,
the
data
are
not
substantial
enough
to
quantitatively
incorporate
­
35
­
­
into
the
water
assessments.
Additionally,
it
is
not
clear
in
most
cases
whether
the
water
bodies
and
wells
sampled
correspond
with,
or
were
targeted
to
correspond
with,
PCNB
usage
in
terms
of
location
or
time.
Subsequently,
when
the
registrants
submitted
study­
specific
information
from
a
number
of
monitoring
studies
previously
submitted
in
summary
form,
the
Agency
concluded
that
the
data
do
not
support
the
registrants'
contention
that
a
weight­
of­
evidence
approach
incorporating
the
newly­
submitted
monitoring
data
would
indicate
that
modeled
values
were
too
high.
This
later
review,
in
its
entirety,
may
be
viewed
the
"
Review
of
Surface
Water
Monitoring
Data
(
Summary
Report
and
Original
Monitoring
Reports)
Submitted
to
Support
PCNB
Reregistration,
July
19,
2005,"
which
has
been
posted
to
the
PCNB
docket.

6.
Estimated
Concentrations
of
PCNB
and
Metabolites
in
Water
Resources
a)
Estimated
Environmental
Concentrations
(
EECs)
for
the
Ecological
Risk
Assessment
Environmental
fate
parameters
and
use
characteristics
were
input
to
PRZM/
EXAMS
modeling
to
yield
estimates
of
environmental
concentrations
for
use
in
the
PCNB
ecological
risk
assessment.
The
use
parameters
used
in
the
model
are
those
associated
with
PCNB
as
currently
registered.
Table
16
shows
input
values
for
the
five
scenarios
modeled
in
this
manner.
The
EECs
are
based
on
data
for
residues
of
the
parent,
PCA,
PCTA,
pentachlorobenzene,
pentachlorophenol,
PCTASO,
PCTASO2
and
HCB,
including
volatiles.
­
36
­
­
Table
16.
Selected
input
parameters
for
EECs
of
PCNB
plus
metabolites
Parameter
Value
Source
and/
or
Comments
Application
Rate:
lb
ai/
A/
application
(
turf:
2
applications/
year,
21­
day
interval;

others:
1
application/
year)
turf:
32.67
peanuts:
10
cabbage
(
cole
crop):
30
potatoes:
25
cotton:
2
product
labels
Date
of
First
Application
turf:
November
15
peanuts:
April
15
cabbage:
August
15
potatoes:
May
20
cotton:
April
20
USDA
Crop
Profiles:
http://
www.
ipmcenters.
org
/
CropProfiles/

Application
Type;
Depth
of
Incorporation
turf,
foliar/
ground
spray;
0
cm
peanuts,
band/
ground
spray;
0
cm
cabbage,
broadcast
spray;
10
cm
potatoes,
granular;
10
cm
cotton,
in­
furrow
spray;
0
cm
product
labels
Soil
Partition
Coefficient
(
Kd;
in
mL/
g)
15.5
(
lowest
non­
sand
value)
MRID
416482­
01
Aerobic
Soil
Metabolism
Half­
life
t1/
2
=
1124
days
(
total
residues;
90th
percentile
of
upper
confidence
bound
on
mean
of
two
values
)
MRID
#
s
429119­
02,
413845­
01,
417132­
02,
421128­
01
Spray
Drift
Fraction
(
ground
spray)
0.01
Application
Efficiency
0.99
input
parameter
guidance
Molecular
Weight
295.3
g/
mole
Vapor
Pressure
1.13
x
10­
4
Torr
Henry's
Law
Constant
4.42
x
10­
5
atm­
m3­
mol
product
chemistry
data
Solubility
in
Water
at
25oC
4.4
ppm
10X
solubility
limit
of
0.44
ppm,
per
input
parameter
guidance
Aerobic
Aquatic
Metabolism
Half­
life
t1/
2
=
2248
days
(
total
residues)*
2X
aerobic
soil
metabolism
t1/
2
per
input
parameter
guidance
­
37
­
­
Parameter
Value
Source
and/
or
Comments
Anaerobic
Aquatic
Metabolism
Half­
life
t1/
2
=
2004
days
(
total
residues)*
2X
anaerobic
soil
metabolism
t1/
2
per
input
parameter
guidance;
data
from
MRID
413843­
01
Hydrolysis
Half­
life
@
pH
7
stable
MRID
#
s
408653­
01,
409726­
01
Aquatic
Photolysis
Half­
life
1.83
days
@
pH
5
MRID
#
s
426062­
01
and
­
02,
423362­
01
*
empirical
data
lacking;
values
derived
from
soil
metabolism
data
as
described
in
risk
assessment
Results
of
the
PRZM/
EXAMS
modeling
for
PCNB
and
metabolites,
for
selected
uses
as
currently
labeled,
are
found
in
Table
17.
Peak
concentrations
are
used
to
calculate
acute
RQs
and
the
1­
in­
10­
year
concentrations
are
used
to
calculate
chronic
RQs.
A
1­
in­
10
year
value
is
a
value
that
would
be
equaled
or
exceeded
once
every
ten
years,
on
average.
One­
in­
ten­
year
means
are
estimated
from
running
averages
of
21
and
60
days.

Table
17.
Surface
Water
Concentrations
for
Use
in
the
Ecological
Risk
Assessment
Use
Site
(
Rate/
Year)
Peak
(
Acute
Assessment)
1­
in­
10­
Year
21­
day
(
Fish
Chronic
Assessment)
1­
in­
10­
Year
60­
day
(
Invertebrate
Chronic)

Cabbage
(
30
lb
ai/
A)
84
ppb
56
ppb
36
ppb
Cotton
(
2
lb
ai/
A)
28
ppb
20
ppb
14
ppb
Peanuts
(
10
lb
ai/
A)
97
ppb
46
ppb
25
ppb
Potato
(
25
lb
ai/
A)
22
ppb
11
ppb
5
ppb
Turf
(
32.67
lb
ai/
A,
2X)
259
ppb
187
ppb
139
ppb
Detailed
information
on
the
modeling
and
complete
results
are
presented
in
Appendix
D6
of
the
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,
February
15,
2005."
Water
concentrations
used
for
the
ecological
RQs
have
been
recalculated
to
reflect
proposed
mitigation.
The
revised
EECs
are
discussed
in
Section
IV.
­
38
­
­
b)
Drinking
Water
Concentrations
The
water
concentration
used
to
estimate
dietary
risk
is
shown
in
Table
5
above.
The
value
was
derived
from
PRZM/
EXAMS
modeling
of
physical­
chemical
properties
of
PCNB
and
PCA
and
the
high­
end
application
parameters
for
PCNB
use
on
turf.
Even
though
concentrations
of
PCNB
in
groundwater
from
use
of
PCNB
on
ornamental
bulbs
are
estimated
to
be
higher,
the
drinking
water
assessment
relies
on
the
surface
water/
turf
values
because
of
the
extent
of
turf
use
and
the
predominance
of
surface
water
as
the
source
of
drinking
water.
Water
concentrations
for
the
drinking
water
assessment
have
been
recalculated
to
reflect
proposed
mitigation,
as
discussed
in
Section
IV.

7.
Estimates
of
Ecological
Risk
The
Agency
typically
estimates
ecological
risk
by
calculating
the
ratio
of
EECs
to
ecotoxicity
values.
These
risk
quotients
(
RQs)
are
then
compared
to
LOCs
used
by
the
Agency
to
indicate
potential
risk
to
nontarget
organisms
and
the
need
to
consider
regulatory
action.
As
noted
above,
the
fate
characteristics
of
PCNB
and
its
metabolites
cannot
be
fully
accounted
for
in
developing
the
RQs,
and
so
contribute
to
the
underestimation
of
risks.
When
they
are
available
and
of
good
quality,
the
results
of
field
studies
and
incident
data
may
add
to
the
weight­
ofevidence
LOCs
are
established
for
duration
of
exposure
(
acute
and
chronic),
wildlife
type
(
e.
g.,
mammals
and
birds,
fish
and
aquatic
invertebrates),
and
endangered
species.
The
standard
LOCs
and
the
corresponding
risk
presumptions
are
presented
in
Table
18.

Table
18.
LOCs
and
Risk
Presumptions
IF...
THEN
the
Agency
presumes...

Mammals
and
Birds
The
acute
RQ
>
LOC
of
0.5
Acute
risk
The
acute
RQ
>
LOC
of
0.1
Acute
effects
may
occur
in
Endangered
Species
The
chronic
RQ
>
LOC
of
1
Chronic
risk
and
Chronic
effects
may
occur
in
Endangered
Species
Fish
and
Aquatic
Invertebrates
The
acute
RQ
>
LOC
of
0.5
Acute
risk
The
acute
RQ
>
LOC
of
0.05
Acute
effects
may
occur
in
Endangered
Species
The
chronic
RQ
>
LOC
of
1
Chronic
risk
and
Chronic
effects
may
occur
in
Endangered
Species
Terrestrial
and
Aquatic
Plants
The
acute
RQ
>
LOC
of
1
Acute
effects
may
occur
in
Endangered
Species
­
39
­
­
The
combination
of
uses
and
application
methods
for
PCNB,
and
the
particular
fate
characterstics
of
PCNB
and
its
metabolites,
result
in
many
potential
routes
of
exposure
to
nontarget
terrestrial
and
aquatic
organisms.
For
the
terrestrial
exposure
assessment
(
birds
and
mammals),
food
item
exposures
resulting
from
seed
treatment
and
foliar
applications
are
the
major,
quantifiable
routes
of
exposure;
for
aquatic
exposures,
residues
in
water
from
soil
and
foliar
applications
are
quantified.

RQs
for
ecological
risk
have
been
reassessed
based
on
proposed
mitigation
and
the
use
of
a
more
refined
model
for
terrestrial
risk.
These
risk
assessments
are
discussed
in
more
detail
in
Section
V
of
this
RED.

a)
Risk
to
Birds
(
1)
Avian
Toxicity
Table
19
summarizes
the
avian
toxicity
endpoints
associated
with
PCNB.

Table
19.
PCNB
Toxicity
Data
for
Avian
Species
Species
5­
day
LC50
(
ppm)
Subacute
Dietary
Toxicity
NOEC/
LOEC
(
ppm)
Affected
Endpoints
Northern
bobwhite
quail
>
54,000
practically
non­
toxic
600/
1200
Reproduction
Mallard
duck
>
54,000
practically
non­
toxic
600/
1200
Growth
For
both
test
species,
there
was
no
mortality
even
at
the
highest
dose
tested.
The
Agency
believes
that
PCNB
is
practically
non­
toxic
to
birds
on
both
an
acute
and
subacute
dietary
basis
The
Agency
considers
measures
of
toxicity
to
birds
to
serve
as
surrogates
for
toxicity
to
reptiles
and
terrestrial­
phase
amphibians,
so
PCNB
is
considered
to
be
highly
toxic
to
these
taxa
as
well.

(
2)
Avian
Exposures
Birds
may
ingest
seed
treated
with
PCNB,
or
they
may
be
exposed
when
consuming
other
food
items
(
plant
parts
and
insects)
contaminated
via
spray
or
chemigation
applications
of
PCNB.
In
addition
to
these
exposures,
which
have
been
quantified
for
the
avian
risk
assessment,
exposure
may
result
from
incidental
ingestion
of
contaminated
soil,
dermal
contact
with
treated
surfaces,
preening
activities,
inhalation
of
pesticide
vapor,
and
ingestion
of
contaminated
drinking
water.

(
a)
Avian
Exposures
from
Treated
Seed
­
40
­
­
Acute
RQs
were
calculated
in
two
ways
for
assessing
risk
from
PCNB­
treated
seeds.
The
first
method
assumes
that
a
bird
eats
(
treated)
seed
only,
and
compares
exposure
from
ingestion
of
treated
seed
to
the
acute
oral
toxicity
endpoint
(
LD50).
The
second
method
compares
the
LD50
to
the
amount
of
pesticide
available
to
birds
in
a
square
foot
of
planted
area.
For
chronic
risks
from
treated
seed,
exposure
is
based
on
peak
concentration
on
the
seed.
Exposures
are
shown
in
Table
21
below,
along
with
corresponding
RQs.

(
i)
Seed
as
Sole
Food
Source
(
Method
1)

The
first
method
of
assessing
acute
risks
from
treated
seeds
is
based
on
the
exposures
to
the
smallest
seed­
eating
birds,
generally
weighing
about
20
g;
small
birds
tend
to
eat
more
per
unit
body
weight
than
larger
birds.
Exposure
is
estimated
from
the
concentration
of
PCNB
on
treated
seed,
using
daily
food
intake
as
estimated
by
Nagy
(
1987).
Seeding
rates
were
obtained
from
crop
profiles
(
found
at
http://
pestdata.
ncsu.
edu/
cropprofiles/
cplist.
cfm?
org=
crop)
or
through
discussions
with
registrants.
LD50s
were
adjusted
to
account
for
the
difference
in
body
weights
between
the
smallest
seed­
eating
birds
and
the
ecotoxicity
test
species
based
on
the
formula
recommended
by
Mineau
et
al.
1996.

(
ii)
PCNB
Per
Square
Foot
(
Method
2)

For
the
second
method
of
assessing
acute
risk
to
birds
from
treated
seed,
it
is
assumed
that
100%
of
the
seed
is
available
for
consumption.
The
Agency
believes
this
is
a
reasonable
assumption
because
the
seed
is
small
and
is
generally
not
planted
deeply
(<
2
inches).
Seed
can
be
planted
by
drill
or
by
broadcast
followed
by
a
drag
chain;
either
method
will
place
the
seed
near
the
surface.
The
amount
of
PCNB
available
for
ingestion
by
birds
is
the
amount
present
on
the
treated
seed,
expressed
on
a
per
square
foot
basis.
The
LD50
(
adjusted
for
different
body
weights)
is
then
multiplied
by
the
weight
of
the
bird
to
yield
the
lethal
dose
of
PCNB.
The
RQ
is
calculated
as
the
ratio
of
the
amount
present
on
the
treated
seed
(
on
a
per
square
foot
basis)
to
the
lethal
dose.

(
b)
Terrestrial
Exposures,
Sprays
and
Chemigation
The
avian
and
mammalian
risk
assessments
for
spray
and
chemigation
applications
presented
in
this
Section
rely
on
EECs
generated
from
a
spreadsheet­
based
model
(
ELL­
FATE)
that
calculates
the
decay
of
a
chemical
applied
to
foliar
surfaces
for
single
or
multiple
applications.
The
exposure
assessment
also
uses
the
methods
of
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994),
which
are
based
on
a
large
set
of
actual
field
residue
measurements
(
including
information
over
a
hundred
plant
species
and
pesticides).
Further
explanation
of
the
models
used
to
estimate
exposures
presented
in
this
Section
is
found
in
Appendix
F
of
the
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Pentachloronitrobenzene,
February
12,
2005."
More
recently,
the
Agency
has
moved
to
an
improved
model
for
assessing
terrestrial
wildlife
exposures
and
risks,
called
TREX,
which
accounts
for
different
diets
and
food
source
preferences
for
different
kinds
of
birds
and
mammals.
Risk
quotients
derived
from
the
TREX
model,
and
taking
into
account
risk
mitigation
measures
proposed
by
the
registrants,
are
presented
in
Section
IV
of
this
RED.
­
41
­
­
Terrestrial
EECs
for
nongranular
formulations
were
calculated
for
cole
crops,
cotton,
peanuts,
and
turf,
using
labeled
application
parameters.
EECs
were
calculated
for
four
categories
of
food
items
potentially
contaminated
with
residues
as
a
result
of
the
PCNB
applications:
short
grass;
tall
grass;
broadleaf
plants
and
small
insects;
and
fruits,
pods,
seeds,
and
large
insects.
EECs
for
PCNB
are
always
highest
on
short
grass
and
for
smaller
birds,
and
lowest
on
fruits,
pods,
seeds,
and
large
insects
and
for
larger
birds,
with
concentrations
on
the
short
grass
more
than
an
order
of
magnitude
higher.
A
summary
of
environmental
exposures
estimated
in
this
way
is
found
in
Table
20.

Uncertainties
in
the
terrestrial
EECs
are
primarily
associated
with
a
lack
of
data
on
interception
and
subsequent
dissipation
from
foliar
surfaces.
When
such
data
are
lacking,
as
in
this
case,
EFED
assumes
a
35­
day
foliar
dissipation
half
life,
based
on
the
work
of
Willis
and
McDowell
(
1987).
The
assumption
is
a
conservative
one
for
foliar
surfaces,
because
even
a
persistent
chemical
like
PCNB
will
be
washed
off
leaves
by
rain
or
dew.
Given
that
PCNB
residues
have
been
shown
to
remain
in
agricultural
fields
for
several
years
after
the
last
application,
residues
may
remain
in
grit
well
beyond
the
35­
day
half­
life.

Table
20.
EECs
on
Bird/
Mammal
Food
Items
from
Spray
and
Chemigation
Applications
Use
site
Application
rate
modeled
(#
applications/
interval,
if
relevant)
Maximum
EECs
(
ppm),
for
acute
assessment
Mean
EECs
(
ppm)
for
chronic
assessment
Cole
crops
(
Cabbage)
22.5
lbs
ai/
A*
(
1
application)
338
to
5400
158
to
1913
10
lbs
ai/
A
(
1
application)
150
to
2400
70
to
850
5
lbs
ai/
A
(
2
applications/
30
days)
116
to
1862
54
to
660
Peanuts
3.2
lbs
ai/
A
(
3
applications/
7
days)
128
to
2049
60
to
726
Potato
5.0
lbs
ai/
A
(
4
applications/
7
days)
247
to
3946
115
to
1397
Turf
43.56
lbs
ai/
A
(
2
applications/
7
days)
1222
to
19555
570
to
6926
*
not
the
highest
rate
on
current
labels
for
this
use
(
3)
Avian
Risk
Quotients
­
42
­
­
(
a)
From
Ingestion
of
PCNB­
Treated
Seed
Acute
and
Chronic
RQs
associated
with
treated
seed
are
shown
in
Table
21.

Table
21.
Avian
Acute
and
Chronic
Risk
Quotients
for
PCNB­
treated
Seed
Crop
EEC
mg
ai/
day
Acute
RQ
Method
1a
EEC
mg
ai/
ft2
Acute
RQ
Method
2b
EEC
mg/
kg
seed
Chronic
RQc
Barley
296
<
0.19
1.22
<
0.04
1171
2.0d
Bean
119
<
0.07
0.78
<
0.02
469
0.78
Corn
119
<
0.07
0.12
<
0.01
469
0.78
Cotton
573
<
0.36
0.43
<
0.01
2265
3.8d
Oats
435
<
0.27
2.29
<
0.07
1718
2.9d
Peas
237
<
0.15
1.76
<
0.06
937
1.6d
Peanuts
138
<
0.09
0.77
<
0.02
547
0.91
Rice
352
<
0.22
2.32
<
0.07
1390
2.3d
Sorghum
69
<
0.04
0.02
<
0.01
273
0.46
Soybeans
237
<
0.15
0.98
<
0.03
937
1.6d
Sugar
Beets
425
<
0.27
0.14
<
0.01
1679
2.8d
a
Acute
RQ
Method
1
=
mg
kg­
1
day­
1
/
LD50
b
Acute
RQ
Method
2
=
mg
ft2
/
LD50
c
Chronic
RQ
=
mg
kg­
1
seed
/
NOAEC
d
Exceeds
chronic
risk
level
of
concern,
RQ
>
1.0
PCNB
is
practically
nontoxic
to
birds
on
an
acute
exposure
basis
(
no
mortality
was
observed
at
the
highest
dose
tested
in
birds).
The
Agency's
concern
for
birds
is
primarily
with
chronic
exposures.
Chronic
RQs
exceed
levels
of
concern
for
seven
of
the
11
seed
types
that
were
assessed.
(
b)
From
Spray
and
Chemigation
Applications
Acute
and
chronic
RQs
associated
with
selected
non­
seed
treatment
uses
of
PCNB
(
as
currently
labeled),
for
a
range
of
food
items
and
sizes
of
bird,
are
summarized
in
Table
22.
The
use
parameters
used
to
generate
these
RQs
are
shown
in
Table
20.
­
43
­
­
Table
22.
Avian
Risk
Quotients
from
Spray
and
Chemigation
Applications
Use
site
Range
of
acute
RQs
Range
of
chronic
RQs
Cole
crops
(
Cabbage)
<
0.01
to<
0.10
0.56
to
9.01
Peanuts
<
0.01
to<
0.04
0.19
to
4.01
Potato
<
0.01
to<
0.07
0.41
to
6.61
Turf
<
0.02
to
<
0.36
2.01
to
331
1
exceeds
chronic
risk
level
of
concern
PCNB
is
practically
nontoxic
to
birds
on
an
acute
exposure
basis
(
no
mortality
was
observed
at
the
highest
dose
tested
in
birds).
The
Agency's
concern
for
birds
is
primarily
with
chronic
exposures.
For
the
modeled
uses,
as
currently
labeled,
chronic
RQs
exceed
LOCs
(
RQ
>
1)
in
many
instances.
When
the
impact
of
environmental
loading
is
factored
in,
risks
would
be
higher
than
those
represented
by
risk
quotients
alone.
Risk
Quotients
for
birds
and
spray
and
chemigation
applications
of
PCNB
have
been
reassessed
with
the
improved
model
TREX
and
based
on
the
registrant
risk
mitigation
proposal.
This
reassessment
is
discussed
in
Section
IV
of
this
RED.

b)
Risk
to
Mammals
(
1)
Mammalian
Toxicity
Table
23
summarizes
mammalian
toxicity
endpoints
for
PCNB.

Table
23.
PCNB
Toxicity
Data
for
a
Representative
Mammalian
Species
Species
LD50
in
ppm
Acute
oral
toxicity
(
MRID#)
NOAEC
in
ppm
(
MRID#)
Chronic
Endpoints
Laboratory
rat
Rattus
norvegicus
>
5050
practically
non­
toxic
(
414431­
01)
200
(
434693­
03)
liver,
thyroid
hypertrophy;
thyroid
follicular
cell
hyperplasia
In
the
rat
acute
oral
study,
no
mortality
was
seen
even
at
the
highest
dose
tested.
The
Agency
believes
that
PCNB
is
practically
nontoxic
to
mammals
on
an
acute
oral
exposure
basis.
Chronic
RQs
are
based
on
the
NOAEC
from
a
two­
generation
rat
reproduction
study.
The
relationship
of
the
endpoints
in
this
study
(
liver
and
thyroid
effects)
to
more
typical
ecological
assessment
endpoints
(
e.
g.,
impaired
reproduction,
growth
and
survival)
is
not
clear.

(
2)
Mammalian
EECs
­
44
­
­
Mammalian
exposures
from
treated
seed
were
calculated
in
the
same
manner
as
that
described
above
for
birds.
Exposures
are
shown
in
Table
24
below.

Potential
exposures
resulting
from
spray
and
chemigation
applications
of
PCNB
were
calculated
for
mammals
in
the
same
way
as
for
birds,
with
the
same
use
sites
and
application
parameters.
The
range
of
potential
exposures
for
mammals
can
be
found
in
Table
20
above.

(
3)
Mammalian
Risk
Quotients
(
a)
From
Ingestion
of
PCNB­
Treated
Seed
Table
24
shows
the
EECs
and
RQs
for
acute
and
the
chronic
mammalian
exposures
from
ingestion
of
treated
seed.

Table
24.
Mammalian
Risk
Quotients
for
Ingestion
of
Treated
Seed
Crop
EEC
mg
ai/
day
Acute
RQ
Method
1a
EEC
mg
ai/
ft2
Acute
RQ
Method
2b
EEC
mg/
kg
seed
Chronic
RQc
Barley
172
<
0.02
1.22
<
0.01
1171
5.9d
Bean
69
<
0.01
0.78
<
0.01
469
2.3d
Corn
69
<
0.01
0.12
<
0.01
469
2.3d
Cotton
332
<
0.04
0.43
<
0.01
2265
11d
Oats
252
<
0.03
2.29
<
0.02
1718
8.6d
Peas
137
<
0.02
1.76
<
0.01
937
4.7d
Peanuts
80
<
0.01
0.77
<
0.01
547
2.7d
Rice
204
<
0.02
2.32
<
0.01
1390
7.0d
Sorghum
40
<
0.01
0.02
<
0.01
273
1.4d
Soybeans
137
<
0.02
0.98
<
0.01
937
4.7d
Sugar
Beets
246
<
0.03
0.14
<
0.01
1679
8.4d
Wheat
69
<
0.01
0.66
<
0.01
469
2.3d
a
Acute
RQ
Method
1
=
mg
kg­
1
day­
1
/
LD50
b
Acute
RQ
Method
2
=
mg
ft2
/
LD50
c
Chronic
RQ
=
mg
kg­
1
seed
/
NOAEC
d
Exceeds
chronic
risk
level
of
concern
(
RQ
>
1)
­
45
­
­
PCNB
is
practically
nontoxic
to
mammals
on
an
acute
oral
exposure
basis.
The
Agency
considers
the
likelihood
of
acute
mortality
to
mammals
to
be
low
for
the
modeled
uses.
Chronic
risk
LOC
(
RQ
>
1)
is
exceeded
for
every
type
of
treated
seed.

(
b)
From
Spray
and
Chemigation
Applications
RQs
were
calculated
for
mammals
of
three
sizes.
RQs
are
shown
in
Table
25;
use
parameters
used
to
generate
these
RQs
are
as
in
Table
20.

Table
25.
Acute
RQs
for
Mammals
PCNB
is
practically
nontoxic
to
mammals
on
an
acute
basis.
The
Agency
considers
the
likelihood
of
mammalian
acute
mortality
to
be
low
for
all
of
the
modeled
uses.

Chronic
risk
quotients
from
spray
and
chemigation
applications
for
mammals
are
based
on
a
NOAEC
of
200
ppm,
but
the
relevance
of
the
thyroid
and
liver
effects
from
this
study
of
laboratory
rats
to
more
relevant
ecological
assessment
endpoints
of
impaired
reproduction,
growth
and
survival
in
wildlife
is
not
clear.
Chronic
RQs
were
calculated
for
different
food
sources
and
mammals
in
a
range
of
three
sizes.
RQs
are
shown
in
Table
26;
use
parameters
are
those
shown
in
Table
20.

Table
26.
Chronic
mammalian
risk
quotients
for
selected
uses
of
nongranular
products
Range
of
Chronic
Mammalian
RQs
(
by
animal
wt.)
Use
Site
15
g
35
g
1000
g
Cole
crops
(
Cabbage)
71
to
5131
51
to
3561
11
to
811
Peanuts
21
to
2281
21
to
1581
0.35
to
361
Potato
51
to
3751
41
to
2601
0.74
to
591
Turf
261
to
18581
181
to
12911
41
to
2931
1
exceeds
chronic
risk
of
concern
Range
of
Acute
Mammalian
RQs
(
by
animal
weight)
Use
site
15
g
35
g
1000
g
Cole
crops
(
Cabbage)
<
0.01
to
<
1.0
<
0.01
to
<
0.71
<
0.01
to
<
0.16
Peanuts
<
0.01
to
<
0.45
<
0.01
to
<
0.31
<
0.01
to
<
0.07
Potato
<
0.01
to
<
0.74
<
0.01
to
<
0.52
<
0.01
to
<
0.12
Turf
<
0.05
to
<
3.7
<
0.04
to
<
2.6
<
0.01
to
<
0.58
­
46
­
­
For
the
majority
of
the
selected
uses
sites,
as
currently
labeled,
the
chronic
mammalian
chronic
risk
LOC
(
RQ
>
1)
is
exceeded
for
all
sizes
of
animal
and
food
items
evaluated.
When
the
impact
of
environmental
loading
is
factored
in,
risks
would
be
higher
than
those
represented
by
risk
quotients
alone.
Risk
Quotients
for
mammals
and
spray
and
chemigation
applications
of
PCNB
have
been
reassessed
with
the
improved
model
TREX
and
based
on
the
registrant
risk
mitigation
proposal.
This
reassessment
is
discussed
in
Section
IV
of
this
RED.

c)
Risk
to
Fish
and
Aquatic
Invertebrates
Tables
27
and
28
summarize
the
toxicity
endpoints
used
in
the
hazard
assessment
of
aquatic
species
for
PCNB.

(
1)
Toxicity
to
Freshwater
Species
Table
27.
Acute
and
chronic
toxicity
data
for
freshwater
species
Acute
Toxicity
Chronic
Toxicity
Species
96­
hr
LC50
(
mg/
L)
Acute
Toxicity
NOEC/
LOEC
(
mg/
L)
Endpoints
Freshwater
fish
Rainbow
trout
Oncorhynchus
mykiss
0.32
highly
toxic
0.013/
0.032
reduced
growth
and
reproduction
Bluegill
sunfish
Lepomis
macrochirus
0.10
highly
toxic
­­
­­

Rainbow
trout
Oncorhynchus
mykiss
(
formulated
product)
0.31
highly
toxic
­­
­­

Bluegill
sunfish
Lepomis
macrochirus
(
formulated
product)
0.24
highly
toxic
­­
­­

Freshwater
invertebrate
Water
flea
Daphnia
magna
0.77
(
48h
LC50)
highly
toxic
0.018/
0.030
reduced
growth
and
reproduction
PCNB
is
highly
toxic
to
freshwater
fish
and
invertebrates
on
an
acute
exposure
basis.
The
Agency
considers
measures
of
toxicity
to
freshwater
fish
to
serve
as
surrogates
for
toxicity
to
aquatic­
phase
amphibians,
so
PCNB
is
considered
to
be
highly
toxic
to
aquatic­
phase
amphibians
as
well.
­
47
­
­
(
2)
Toxicity
to
Estuarine/
Marine
Species
Table
28.
Acute
Toxicity
Data
for
Estuarine/
Marine
Species
Species
96­
hr
LC50
(
in
mg/
L)
Acute
Toxicity
Estuarine/
Marine
Fish
Sheepshead
minnow
(
Cyprinodon
variegatus)
7.9
moderately
toxic
Estuarine/
Marine
Invertebrates
Eastern
oyster
(
Crassostrea
virginica)
0.023
very
highly
toxic
Mysid
shrimp
(
Mysidopsis
bahia)
0.012
very
highly
toxic
PCNB
is
moderately
toxic
to
estuarine/
marine
fish
and
very
highly
toxic
to
estuarine/
marine
invertebrates
on
an
acute
exposure
basis.
Chronic
data
are
lacking
for
estuarine/
marine
species.
Since
estuarine/
marine
invertebrates
are
more
sensitive
to
PCNB
on
an
acute
basis
than
their
freshwater
counterparts,
it
is
reasonable
to
assume
that
they
may
be
more
sensitive
on
a
chronic
exposure
basis
as
well.

(
3)
Exposure
for
Aquatic
Species
Surface
water
concentrations
resulting
from
PCNB
application
to
five
selected
crops,
as
currently
labeled,
were
estimated
with
the
Tier
II
model
PRZM­
EXAMS.
The
results
of
this
modeling
are
summarized
in
Table
17
above.

(
4)
Risk
Quotients
for
Aquatic
Species
Peak
EECs
as
derived
from
the
PRZM­
EXAMS
model
were
compared
to
acute
toxicity
endpoints
for
aquatic
species
to
derive
acute
risk
quotients.
There
are
no
chronic
toxicity
data
for
PCNB
in
estuarine/
marine
animals,
so
chronic
risk
quotients
could
not
be
generated
for
these
species.
The
results
of
these
assessments
are
summarized
in
Tables
29
(
freshwater
animals)
and
30
(
estuarine/
marine
animals).
­
48
­
­
Table
29.
Acute
and
chronic
risk
quotients
for
freshwater
animals
exposed
to
PCNB
Acute
RQs
Chronic
RQs
Use
site
(
application
parameters
as
in
Table
16)
Freshwater
Fish
Freshwater
Invertebrates
Freshwater
Fish
Freshwater
Invertebrates
Cole
crops
0.841
0.112
4.33
3.13
Cotton
0.282
0.04
1.53
1.13
Peanuts
0.971
0.132
3.53
2.63
Potatoes
0.222
0.03
0.8
0.6
Turf
2.61
0.342
8.23
5.93
1
exceeds
acute
risk
to
nonlisted
species
(
RQ
>
0.5)
and
endangered
species
(
RQ
>
0.05)
LOCs
2
exceeds
acute
risk
to
endangered
species
LOC
(
RQ
>
0.05)
3
exceeds
chronic
risk
LOC
(
RQ
>
1)

Table
30.
Acute
risk
quotients
for
estuarine/
marine
animals
exposed
to
PCNB
Acute
RQs
Crop
(
application
parameters
as
in
Table
16)
Estuarine/
Marine
Fish
Estuarine/
Marine
Invertebrates
Cole
crops
0.01
7.01
Cotton
<
0.01
2.31
Peanuts
0.01
8.11
Potatoes
<
0.01
1.81
Turf
0.03
221
1
exceeds
acute
risk
to
nonlisted
species
(
RQ
>
0.5)
and
endangered
species
(
RQ
>
0.05)
LOCs
For
these
uses
as
currently
labeled,
acute
risk
LOCs
for
nonlisted
species
are
exceeded
for
freshwater
fish
following
application
to
cole
crops,
peanuts,
and
turf;
acute
risk
endangered
species
LOCs
are
exceeded
for
all
sites.
The
chronic
risk
LOC
is
exceeded
for
freshwater
fish
and
invertebrates
on
all
sites
but
potatoes.

While
no
acute
risk
LOCs
for
estuarine/
marine
fish
are
exceeded
for
any
of
the
crops,
the
likelihood
of
adverse
chronic
effects
is
uncertain
since
no
data
are
available
to
assess
the
chronic
toxicity
of
PCNB
in
these
species.
Estuarine/
marine
invertebrates
appear
to
be
much
more
sensitive
to
PCNB
than
their
freshwater
counterparts
on
an
acute
exposure
basis;
based
on
the
chronic
RQs
for
invertebrates
in
Table
29,
it
is
reasonable
to
assume
that
the
chronic
risk
LOC
may
be
exceeded
for
estuarine/
marine
invertebrates.
Based
on
this
uncertainty,
the
Agency
presumes
chronic
risk
to
estuarine/
marine
animals.
­
49
­
­
Risk
quotients
for
aquatic
species
have
been
reassessed
based
on
the
risk
mitigation
proposal
submitted
by
the
registrants,
as
discussed
in
Section
IV
of
this
RED.

d)
Risks
to
Insects
PCNB
is
practically
nontoxic
to
bees
on
an
acute
exposure
basis
(
LD50>
0.1
µ
g/
bee).
The
Agency
did
not
conduct
a
risk
assessment
for
nontarget
insects.

e)
Risks
to
Terrestrial
and
Aquatic
Plants
No
data
are
available
on
the
toxicity
of
PCNB
to
terrestrial
or
aquatic
plants.
The
Assessment
Tools
for
the
Evaluation
of
Risk
(
ASTER)
model,
which
relies
on
structure­
activity
relationships,
suggests
that
the
toxicity
of
chlorinated
benzenes
like
PCNB
increases
with
the
number
of
chlorine
atoms.
Further
discussion
of
the
ASTER
model
and
its
implications
for
PCNB
can
be
found
in
the
"
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Pentachloronitrobenzene,"
February
15,
2005.

8.
Risk
to
Endangered
Species
The
risk
assessment
for
PCNB
indicates
a
potential
for
acute
and
chronic
risks
to
listed
species
associated
with
the
modeled
use
sites.
These
risks
have
been
reassessed
pursuant
to
mitigation
measures
proposed
by
the
registrants,
as
detailed
in
Section
IV.
A
full
accounting
of
risks
to
listed
species
is
made
in
that
Section.

The
Agency
can
not
preclude
the
potential
for
indirect
effects
to
listed
species
that
may
be
dependent
upon
taxa
that
experience
direct
effects
from
the
use
of
PCNB.
These
findings
are
based
solely
on
EPA's
screening­
level
assessment
and
do
not
constitute
"
may
affect"
findings
under
the
Endangered
Species
Act
(
ESA)
for
any
listed
species.

To
address
concerns
about
risks
to
Federally­
listed
endangered
and
threatened
species
from
pesticide
use,
the
Agency
has
developed
the
Endangered
Species
Protection
Program
(
ESPP).
The
assessments
of
risk
for
aquatic
and
terrestrial
wildlife
described
in
this
RED
serve
as
a
screening
tool
to
determine
the
need
for
any
species­
specific
assessments
for
PCNB
and
listed
species.
In
accordance
with
the
ESPP,
EPA
will
consider
ecological
parameters,
use
information,
and
geographic
relationships,
as
well
as
biological
requirements
and
behavioral
aspects
of
a
particular
species
to
develop
a
species­
specific
assessment
for
listed
species.
The
Agency's
species­
specific
analysis
also
will
take
into
consideration
any
risk
mitigation
measures
implemented
as
part
of
the
RED
decision
for
PCNB.

Following
this
future
species­
specific
analysis,
a
determination
whether
there
is
a
likelihood
of
potential
effects
to
a
listed
species
may
result
in
additional
limitations
on
the
use
of
PCNB,
other
measures
to
mitigate
any
potential
effects,
or
consultations
with
the
Fish
and
Wildlife
Service
and/
or
the
National
Marine
Fisheries
as
appropriate.
If
the
Agency's
speciesspecific
assessments
result
in
the
need
to
modify
the
use
of
the
pesticide
in
specific
geographic
­
50
­
­
areas,
those
changes
will
be
undertaken
through
the
process
described
in
the
Agency
Federal
Register
Notice
(
54
FR
27984)
on
implementation
of
the
Endangered
Species
Protection
Program.

Until
a
species­
specific
analysis
is
completed,
the
ecological
risk
mitigation
measures
being
implemented
through
the
RED
will
reduce
the
likelihood
that
endangered
and
threatened
species
may
be
exposed
to
PCNB.
Information
about
the
Agency's
assessment
process
for
threatened
and
endangered
species
is
posted
at
www.
epa.
gov/
espp.

9.
Ecological
Incident
Reports
One
incident
has
been
recorded
for
PCNB
in
the
Ecological
Incident
Information
System
(
EIIS),
for
cotton
seed
which
failed
to
germinate
following
an
unincorporated
granular
application.

IV.
Risk
Management,
Reregistration,
and
Tolerance
Reassessment
Decision
A.
Determination
of
Reregistration
Eligibility
Section
4(
g)(
2)(
A)
of
FIFRA
calls
for
the
Agency
to
determine,
after
submission
of
relevant
data
concerning
an
active
ingredient,
whether
or
not
products
containing
the
active
ingredient
are
eligible
for
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
PCNB
as
an
active
ingredient.
The
Agency
has
completed
its
review
of
these
generic
data,
and
has
determined
that
the
data
are
sufficient
to
formulate
the
reregistration
eligibility
decision
for
products
containing
PCNB.

The
Agency
has
completed
its
assessment
of
the
dietary,
occupational,
residential,
environmental,
and
ecological
risks,
and
the
benefits
associated
with
the
use
of
pesticide
products
containing
the
active
ingredient
PCNB.
Based
on
the
assessments
and
on
public
comments
on
the
assessments,
the
Agency
is
announcing
decisions
about
the
human
health
and
ecological
effects
associated
with
PCNB,
including
tolerance
reassessment
decisions
under
FFDCA
and
reregistration
decisions
under
FIFRA
as
amended
by
FQPA.
The
Agency
has
determined
that
PCNB­
containing
products
for
some
uses
are
eligible
for
reregistration
provided
that
the
risk
mitigation
measures
outlined
in
this
document
are
adopted
and
label
amendments
are
made
to
reflect
those
mitigation
measures.
Label
changes
are
described
in
Section
V.
Those
uses
of
PCNB
eligible
for
reregistration
are:

°
Cole
crops
(
products
labeled
for
control
of
clubroot
only)
2
°
Seed
treatments
°
Flowering
bulbs
in
commercial
production
2
The
only
products
for
use
on
cole
crops
which
are
eligible
for
reregistration
are
those
which
are
limited
to
the
cole
crop/
clubroot
combination,
and
no
other
diseases
may
be
added
to
the
label
of
a
registered
product
either
by
amendment
or
through
the
notification
process
(
PR
Notice
98­
10).
­
51
­
­
The
Agency
has
determined
that
the
uses
of
PCNB
on
turf,
residential
ornamentals,
green
beans,
cotton,
potatoes,
dry
beans
and
peas,
garlic,
peanuts,
tomatoes,
peppers,
and
ornamentals
in
commercial
production
(
except
for
flowering
bulbs)
are
not
eligible
for
reregistration
and
must
be
deleted
from
product
labels.
Products
labeled
exclusively
for
one
or
more
of
these
ineligible
uses
will
not
be
eligible
for
reregistration.

Based
on
its
evaluation,
the
Agency
has
determined
that
PCNB
products,
unless
labeled
solely
for
use
on
sites
listed
as
eligible
for
reregistration
and
otherwise
as
specified
in
this
document,
would
present
risks
inconsistent
with
FIFRA.
Accordingly,
should
a
registrant
fail
to
implement
any
of
the
risk
mitigation
measures
identified
in
this
document,
the
Agency
may
take
regulatory
action
to
address
the
relevant
risks.
If
all
changes
outlined
in
this
document
are
incorporated
into
the
product
labels
and/
or
effected
via
product
cancellation,
then
the
risks
associated
with
the
use
of
PCNB
will
be
adequately
mitigated
for
the
purposes
of
this
determination.

B.
Public
Comments
and
Responses
Following
the
release
of
the
Agency's
revised
risk
assessments
and
the
solicitation
of
risk
management
options
for
PCNB,
public
comment
came
primarily
from
the
registrants.
These
comments
were
mostly
technical
in
nature
and
the
Agency
examined
each
comment
to
determine
if
the
risk
assessments
should
be
revised
to
reflect
the
criticisms,
alternative
methodologies,
and
additional
information
they
provided.
Public
comments
on
benefits
were
submitted
by
the
Golf
Course
Superintendents
Association
of
America.
These
comments
were
also
examined
and
considered
in
development
of
the
Agency's
benefits
assessment
for
PCNB.
The
public
comments,
responses
from
the
Agency,
revised
risk
assessments,
and
the
PCNB
benefits
assessment
can
all
be
accessed
through
the
Federal
government­
wide
electronic
docket
management
and
comment
system
at
http://
www.
regulations.
gov/,
in
Docket
Number
OPP­
2004­
0202.

After
the
comment
period
on
the
risk
assessments
closed,
the
registrants
raised
questions
about
an
adsorption
coefficient
used
in
the
drinking
water
assessment
for
turf.
These
questions
led
to
a
minor
modification
of
the
water
assessment.
The
registrants
also
have
proposed
a
number
of
risk
mitigation
measures
for
PCNB.
The
Agency
assessed
risks
as
they
would
be
if
these
measures
were
adopted,
and
has
based
its
reregistration
decision
for
PCNB
on
the
impact
of
these
measures
on
risk:
where
risks
would
be
mitigated
adequately
by
the
mitigation
measures,
and
where
they
would
not,
and
what
additional
measures
would
be
needed
to
reduce
all
risks
below
levels
of
concern.

C.
Regulatory
Position
1.
Food
Quality
Protection
Act
Findings
a)
"
Risk
Cup"
Determination
­
52
­
­
Based
on
available
data,
EPA
has
reassessed
the
tolerances
associated
with
this
pesticide.
EPA
has
determined
that
risk
from
dietary
(
food
sources
only)
exposure
to
PCNB
is
within
its
own
"
risk
cup,"
if
the
risk
mitigation
measures
proposed
by
the
registrants
are
considered.
Based
on
the
risk
mitigation
proposal,
the
chronic
dietary
risk
associated
with
PCNB
for
food
only
is
less
than
100%
of
the
cPAD.

An
aggregate
assessment
was
conducted
for
exposures
through
food,
drinking
water,
and
residential
use,
incorporating
the
adjustments
to
the
drinking
water
assessment
that
would
be
appropriate
if
the
registrants'
risk
mitigation
proposal
were
implemented.
Under
these
conditions,
the
dietary
risk
from
food
and
water
combined
is
less
than
100%
of
the
cPAD.
The
Agency
has
determined
that
the
aggregate
human
health
risks
from
exposures
to
PCNB
are
within
the
risk
cup
(
still
less
than
100%
of
the
cPAD)
only
when
the
exposures
associated
with
residential
uses
of
PCNB
are
eliminated.
Amvac
and
Chemtura
have
proposed
to
terminate
the
residential
turf
uses
of
PCNB.
The
Agency
believes
that
the
use
of
PCNB
on
residential
ornamentals
also
contributes
to
potential
residential
risks
of
concern,
similar
to
those
from
use
on
turf.
Thus,
this
use
is
ineligible
for
reregistration.
Based
on
the
aggregate
assessment,
and
if
all
residential
uses
of
PCNB
are
terminated,
EPA
has
concluded
that
the
tolerances
for
PCNB
meet
FQPA
safety
standards.
In
reaching
this
determination,
EPA
has
considered
the
available
information
on
the
special
sensitivity
of
infants
and
children,
as
well
as
aggregate
exposure
from
food,
water,
and
residential
uses.

b)
Determination
of
Safety
to
U.
S.
Population
The
Agency
has
determined
that
the
established
tolerances
for
PCNB,
with
amendments
and
changes
as
specified
in
this
document,
meet
the
safety
standards
under
the
FQPA
amendments
to
section
408(
b)(
2)(
D)
of
the
FFDCA,
and
that
there
is
a
reasonable
certainty
no
harm
will
result
to
the
general
population
or
any
subgroup
from
the
use
of
PCNB.
In
reaching
this
conclusion,
the
Agency
has
considered
all
available
information
on
the
toxicity,
use
practices,
exposure
scenarios,
and
environmental
behavior
of
PCNB.

c)
Determination
of
Safety
to
Infants
and
Children
EPA
has
determined
that
the
established
tolerances
for
PCNB,
with
amendments
and
changes
as
specified
in
this
document,
meet
the
safety
standards
under
the
FQPA
amendments
to
section
408(
b)(
2)(
C)
of
the
FFDCA,
that
there
is
a
reasonable
certainty
of
no
harm
for
infants
and
children.
The
safety
determination
for
infants
and
children
considers
the
factors
noted
above
for
the
general
population,
but
also
takes
into
account
the
possibility
of
increased
dietary
exposure
due
to
the
specific
consumption
patterns
of
infants
and
children,
as
well
as
the
possibility
of
increased
susceptibility
to
the
toxic
effects
of
PCNB
residues
in
this
population
subgroup.

FQPA
directs
EPA,
in
setting
pesticide
tolerances,
to
use
an
additional
tenfold
margin
of
safety
to
protect
infants
and
children,
taking
into
account
the
potential
for
pre­
and
postnatal
toxicity
and
the
completeness
of
the
toxicology
and
exposure
databases.
The
statute
authorizes
EPA
to
replace
this
tenfold
FQPA
safety
factor
with
a
different
FQPA
factor
only
if
reliable
data
demonstrate
that
the
resulting
level
of
exposure
would
be
safe
for
infants
and
children.
For
­
53
­
­
PCNB,
the
Agency
has
determined
that
an
uncertainty
factor
of
10X
must
be
retained
for
the
dietary
(
chronic),
residential
exposure
(
incidental
oral,
dermal
and
inhalation),
and
aggregate
risk
scenarios
for
PCNB.

No
findings
of
significant
toxicological
concern
were
identified
in
the
submitted
developmental
or
reproductive
toxicity
data,
and
no
neurobehavioral
alterations
or
evidence
of
neuropathological
effects
were
observed
in
the
available
data.
The
Agency's
retention
of
the
10X
factor
relates
to
potential
effects
on
thyroid
function
after
in
utero
exposure
and
in
children
that
would
not
have
been
detected
in
studies
already
undertaken.
There
are
additional
uncertainties
associated
with
the
potential
effects
of
bioaccumulation
of
PCNB
and
metabolites
in
human
systems.
The
Agency's
uncertainty
about
potential
thyroid
effects
after
in
utero
exposure
and
in
children
is
discussed
in
Section
III
of
this
RED.

d)
Endocrine
Disruptor
Effects
EPA
is
required
under
the
FFDCA,
as
amended
by
FQPA,
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticide
active
and
other
ingredients)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally
occurring
estrogen,
or
other
endocrine
effects
as
the
Administrator
may
designate."
When
the
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Endocrine
Disruptor
Screening
Program
have
been
developed,
PCNB
may
be
subject
to
additional
screening
and/
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.
e)
Cumulative
Risks
The
Food
Quality
Protection
Act
(
FQPA)
requires
EPA
to
consider
"
available
information"
concerning
the
cumulative
effects
of
a
particular
pesticide's
residues
and
"
other
substances
that
have
a
common
mechanism
of
toxicity"
when
considering
whether
to
establish,
modify,
or
revoke
a
tolerance.
Potential
cumulative
effects
of
chemicals
with
a
common
mechanism
of
toxicity
are
considered
because
low­
level
exposures
to
multiple
chemicals
causing
a
common
toxic
effect
by
a
common
mechanism
could
lead
to
the
same
adverse
health
effect
as
would
a
higher
level
of
exposure
to
any
one
of
these
individual
chemicals.

PCNB
is
an
organochlorine
member
of
the
substituted
aromatics
class
of
pesticides
(
George
W.
Ware,
The
Pesticide
Book,
Fourth
ed.,
1994).
A
cumulative
risk
assessment
has
not
been
conducted
for
members
of
this
class
of
pesticides
as
part
of
this
human
health
risk
assessment.
Exposure
of
test
animals
with
PCNB
does
not
appear
to
result
in
endpoints
the
same
as
those
resulting
in
test
animals
exposed
to
the
organochlorine
pesticides
chlorothalonil
or
pentachlorophenol.
The
endpoints
used
to
assess
human
health
risks
for
PCNB
are
primarily
thyroid
hypertrophy
and
hepatocellular
hypertrophy
and
hyperplasia.
The
endpoints
for
chlorothalonil
have
been
identified
as
various
kidney
and
forestomach
effects,
and
the
endpoints
identified
for
pentachlorophenol
are
carcinogenicity
(
hemangiosarcomas,
hepatocellular
tumors,
and
adrenal
tumors)
and
developmental
effects
(
increased
resorptions
of
fetuses,
reduced
fetal
weight,
skeletal
malformations
of
fetuses).
The
Agency
has
not
undertaken
a
comprehensive
assessment
of
organochlorine
pesticides
with
respect
to
common
mechanism.
For
information
regarding
EPA's
efforts
to
determine
which
chemicals
have
a
common
mechanism
of
toxicity
and
­
54
­
­
to
evaluate
the
cumulative
effects
of
such
chemicals,
see
the
policy
statements
by
the
EPA's
Office
of
Pesticide
Programs
concerning
common
mechanism
determinations
and
procedures
for
cumulating
effects
from
substances
found
to
have
a
common
mechanism
on
EPA's
website
at
http://
epa.
gov/
pesticides/
cumulative/
.

2.
Tolerance
Summary
The
Agency
has
reassessed
all
current
tolerances
for
PCNB.
The
Agency
has
also
determined
the
eligibility
of
reregistration
for
all
uses
of
PCNB;
the
rationale
for
these
determinations
is
described
later
in
this
Section.
The
Agency
will
give
consideration
to
overseas
use
of
PCNB
and
international
trade
in
determining
whether
to
propose
revocation
of
tolerances
associated
with
uses
of
PCNB
that
are
not
eligible
for
reregistration.
In
proposing
a
schedule
for
revocation,
the
Agency
also
will
take
into
account
the
last
legal
use
date,
movement
through
the
market
of
commodities
with
residues
resulting
from
legal
use,
and
the
persistence
of
PCNB
and
its
metabolites.

The
Agency
has
also
evaluated
residue
data
associated
with
uses
of
PCNB
for
which
tolerances
have
not
yet
been
established.
Some
of
these
uses
are
not
eligible
for
reregistration,
and
the
Agency
will
not
establish
tolerances
for
the
associated
commodities.

The
Agency
believes
that
the
correct
tolerance
expression
for
residues
of
PCNB
and
its
metabolites
is
residues
of
PCNB,
PCA,
and
PCTA.
The
current
tolerance
expressions
for
"
pentachloronitrobenzene"
or
"
pentachloronitrobenzene
(
PCNB)
and
its
metabolites
pentachloroaniline
(
PCA)
and
methyl
pentachlorophenyl
sulfide
(
MPCPS)"
should
be
changed
to
"
pentachloronitrobenzene
(
PCNB)
and
its
metabolites
pentachloroaniline
(
PCA)
and
pentachlorothioanisole
(
PCTA)."
PCTA
and
MPCPS
are
two
different
names
for
the
same
compound.

a)
Tolerances
Currently
Listed
Under
40
CFR
§
180.291(
a)

The
tolerance
expression
in
40
CFR
§
180.291(
a)
for
pentachloronitrobenzene
will
be
changed
to
pentachloronitrobenzene
(
PCNB)
and
its
metabolites
pentachloroaniline
(
PCA)
and
pentachlorothioanisole
(
PCTA).
­
55
­
­
Table
31.
PCNB
Tolerances
Listed
Under
40
CFR
§
180.291(
a)

Commodity
Current
Tolerance
(
ppm)
Tolerance
Reassessment
(
ppm)
Comment
Cottonseed
0.1
TBD*
Confirmatory
residue
data
for
seed
treatment
use
are
currently
in
review.
Conservative
assumptions
have
been
applied
to
ensure
that
dietary
risks
are
not
underestimated.
*
TBD
=
To
be
determined
b)
Tolerances
Currently
Listed
Under
40
CFR
§
180.291(
b)

Tolerances
listed
at
40
CFR
§
180.291
(
b)
will
be
moved
to
40
CFR
§
180.291
(
c)
to
conform
to
the
Agency
standard
for
citing
regional
tolerances.
40
CFR
§
180.291
(
b)
will
be
reserved
for
tolerances
associated
with
Section
18
uses.
The
tolerance
expression
in
40
CFR
§
180.291(
c)
will
be
changed
to
pentachloronitrobenzene
(
PCNB)
and
its
metabolites
pentachloroaniline
(
PCA)
and
pentachlorothioanisole
(
PCTA).
­
56
­
­
Table
32.
Tolerances
Listed
Under
40
CFR
§
180.291(
b)

Commodity
Current
Tolerance
(
ppm)
Tolerance
Reassessment
(
ppm)
Comments
Collards
0.2
0.2
Kale
0.2
0.2
Mustard
Greens
0.2
0.2
Residue
data
from
IR­
4
support
the
current
tolerance
for
regional
registrations.

c)
Interim
Tolerances
Listed
Under
40
CFR
§
180.319
Tolerances
listed
under
§
180.319
will
be
reassigned
to
§
180.291(
a).

Table
33.
Interim
tolerances
Listed
Under
40
CFR
§
180.319
Commodity
Current
Tolerance
(
ppm)
Tolerance
Reassessment
(
ppm)
Comment/
Correct
Commodity
Definition
Beans
0.1
TBD*
Confirmatory
residue
data
for
seed
treatment
use
are
currently
in
review.

Broccoli
Brussels
Sprouts
Cabbage
Cauliflower
0.1
0.1
Head
and
Stem
Brassica
Vegetable
Crop
Subgroup
Garlic
0.1
0.1
Peanuts
1
TBD*
Confirmatory
residue
data
for
seed
treatment
use
are
currently
in
review.

Potatoes
0.1
0.1
Peppers
0.1
Tomatoes
0.1
0.1
Fruiting
Vegetables
(
except
Cucurbits)
Crop
Group
*
TBD
=
To
be
determined.
Conservative
assumptions
have
been
applied
to
ensure
that
dietary
risks
are
not
underestimated.

40
CFR
§
180.291(
d)
will
be
reserved
for
tolerances
associated
with
inadvertent
residues.

d)
Tolerances
That
Need
to
Be
Proposed
Under
40
CFR
§
180.291(
a)

For
several
uses
of
PCNB
resulting
in
residues
in
associated
commodities,
tolerances
have
not
been
proposed
previously.
For
commodities
listed
in
Table
34
with
residues
from
seed
treatment
use,
new
data
may
be
required
pending
approval
of
the
new
analytical
method.
­
57
­
­
Table
34.
Tolerances
That
Need
To
Be
Proposed
under
40
CFR
§
180.291(
a)

Commodity
Tolerance
Assessment
(
ppm)
Comment
Cotton
gin
byproducts
Barley,
grain,
hay
and
straw
Corn,
grain,
forage
and
fodder
Oat,
forage,
grain,
hay
and
straw
Peas
Rice,
grain
and
straw
Safflower,
seed
Sorghum
forage,
grain,
and
stover
TBD*
Confirmatory
residue
data
for
seed
treatment
uses
are
currently
in
review.

Soybean,
forage,
hay
and
seeds
0.02
Sugar
beet,
roots
and
tops
Wheat,
forage,
grain,
hay,
and
straw
Confirmatory
residue
data
for
seed
treatment
uses
are
currently
in
review.

Milk
Cattle
fat,
meat,
and
meat­
byproducts
(
mbyp)

Goat
fat,
meat,
and
mbyp
Horse
fat,
meat,
and
mbyp
Sheep
fat,
meat,
and
mbyp
Hog
fat,
meat,
and
mbyp
Eggs
Poultry,
fat
Poultry,
mbyp
TBD*

*
To
be
determined.
Conservative
assumptions
have
been
applied
to
ensure
that
dietary
risks
are
not
underestimated.

e)
Codex
Harmonization
There
are
no
established
or
proposed
Codex
maximum
residue
limits
(
MRLs)
for
PCNB.

f)
Analytical
Methods
and
Residue
Data
Requirements
The
Agency
has
reassessed
the
current
tolerances
for
PCNB
based
on
the
current
analytical
methodology.
The
current
analytical
method
determines
just
three
compounds
(
parent
+
PCA
+
PCTA).
The
Agency
has
determined
that
a
new
analytical
method
must
be
developed
to
­
58
­
­
account
for
all
metabolites
of
PCNB.
The
Agency
is
requiring
a
new
standardized
analytical
method
for
PCNB
that
converts
all
or
most
of
the
80
plus
residues
of
concern
(
parent
and
metabolites)
to
one
or
a
few
common
moieties
for
use
in
quantifying
total
residues
in
field
trials.
The
new
method
is
needed
because
all
PCNB
metabolites
are
of
toxicological
concern,
are
fairly
stable
in
the
environment,
tend
to
accumulate
in
treated
soil,
are
found
in
rotational
crops,
and
occur
in
varying
ratios.
It
is
possible
that
the
tolerance
expression
for
residues
associated
with
the
use
of
PCNB
will
be
revised
based
on
this
new
method.

The
Agency
is
deferring
a
decision
about
what
additional
data
will
be
needed
for
magnitude
of
residues
until
after
a
new
analytical
method
is
approved.
It
is
possible
that
additional
residue
data
will
be
needed
at
that
time,
and
that
those
data
could
result
in
a
determination
by
the
Agency
that
one
or
more
of
the
tolerance
level
recommendations
made
here
should
be
changed.
Decisions
about
whether
a
new
enforcement
method
is
needed
will
also
be
deferred
until
a
new
analytical
method
is
approved,
so
the
requirement
for
developing
an
enforcement
method
is
reserved.
The
requirement
for
submitting
analytical
reference
standards
is
reserved
on
the
same
basis.

3.
Regulatory
Rationale
The
Agency
has
determined
that
certain
uses
of
PCNB
are
eligible
for
reregistration
provided
that
the
risk
mitigation
measures
outlined
in
this
document
are
adopted,
and
label
amendments
are
made
to
reflect
these
measures,
as
described
in
this
document.

The
following
is
a
summary
of
the
rationale
for
managing
risks
associated
with
the
use
of
PCNB.
Where
labeling
revisions
are
warranted,
specific
language
is
set
forth
in
the
summary
tables
of
Section
V
of
this
document.
The
Agency's
decisions
on
the
reregistration
of
PCNB
are
based
on
the
Agency's
initial
assessment
of
risks,
a
risk
mitigation
proposal
submitted
by
the
registrants,
and
whether
additional
risk
mitigation
is
necessary
to
justify
reregistration.
The
registrants'
risk
mitigation
plan
was
proposed
in
two
parts,
and
the
Agency
also
made
some
technical
refinements
and
an
error
correction
to
its
risk
assessments
during
the
same
interval.
A
chronology
is
provided
below
to
facilitate
understanding
of
the
risks
and
potential
risk
reduction
associated
with
the
registrants'
proposal
and
the
Agency's
changes.
The
Agency's
assessments
and
supporting
documents
identified
in
the
chronology
are
all
available
through
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

a)
Chronology
of
Assessments
and
Mitigation
Proposals
The
Agency
initially
assessed
the
human
health
and
ecological
risks
of
PCNB
as
currently
registered.
The
Agency
also
assessed
the
benefits
associated
with
the
major,
currently
registered
uses
of
PCNB.
The
reregistration
eligibility
decision
for
PCNB
is
based
on
an
evaluation
of
both
risks
and
benefits.
The
risk
assessments
went
through
several
iterations
based
on
public
comments,
proposed
mitigation,
and
the
correction
of
an
error
in
and
refinements
to
the
dietary
assessment.
A
chronology
of
the
Agency
risk
reassessments
and
registrant
responses
may
be
helpful
in
tracking
the
risk
conclusions
discussed
in
this
document.
­
59
­
­
The
Agency
released
risk
assessments
revised
to
address
public
comments
(
mostly
technical
in
nature)
on
March
2,
2005,
and
determined
at
that
time
that
the
dietary,
residential,
aggregate,
ecological,
and
some
occupational
risks
associated
with
the
uses
of
PCNB
were
of
concern.
The
risks
discussed
in
Section
III
of
the
RED
reflect
the
assessments
made
public
in
March
2005.

On
June
10,
2005,
the
two
registrants
of
technical
grade
PCNB,
Amvac
and
Chemtura,
proposed
a
risk
mitigation
plan
focused
mainly
on
reducing
dietary
and
worker
risk.

The
Agency
subsequently
determined
that
the
proposal
adequately
addressed
most
of
the
occupational
risks,
but
that
dietary,
residential,
and
ecological
risks
would
not
be
reduced
below
levels
of
concern.

Subsequent
to
the
Agency's
evaluation
of
this
proposal,
the
registrants
verbally
supplemented
their
original
mitigation
plan
by
proposing
that
all
turf
uses
of
PCNB
except
golf
course
tees,
greens,
and
fairways
be
terminated.
At
the
same
time,
the
Agency
moved
to
correct
an
error
in
its
dietary
risk
assessment
related
to
how
PCNB
residues
partition
in
the
liquid
and
fat
portions
of
milk,
and
to
refine
the
dietary
assessment
by
more
accurately
reflecting
the
composition
of
the
diet
for
lactating
cows
and
its
contribution
to
residues
in
milk.
In
addition,
the
proposal
to
eliminate
all
turf
uses
except
specific
golf
course
sites
allowed
the
Agency
to
incorporate
a
Golf
Course
Adjustment
Factor
(
GCAF)
into
the
drinking
water
and
ecological
water
exposure
assessments
to
represent
the
smaller
portion
of
golf
course
area
on
potentially
treated
with
PCNB.
The
risks
discussed
in
this
Section
of
the
RED
primarily
reflect
the
Agency's
assessment
of
the
registrants'
complete
proposal.

The
Agency
concluded
that
the
registrant's
complete
proposal,
together
with
the
correction
to
and
refinement
of
the
dietary
assessment,
would
decrease
estimates
of
dietary
and
most
of
the
occupational
and
residential
risks
below
levels
of
concern.
The
dietary
risk
conclusions
are
captured
in
an
October
20,
2005
assessment.
Residential
risk
would
be
eliminated
for
applications
to
turf.
Residential
risks
posed
by
the
use
of
PCNB
on
ornamentals
would
not
be
mitigated
by
the
proposal.

Although
the
complete
proposal
would
also
reduce
wildlife
risk
estimates
for
PCNB,
the
Agency
did
not
find
it
adequate
to
address
ecological
risk
concerns.
The
ecological
risk
quotients
associated
with
the
registrants'
proposal
are
captured
in
the
Agency
documents
dated
July
7
and
August
9,
2005.
In
addition
to
risk
quotients
that
exceed
ecological
levels
of
concern
for
most
of
the
assessed
uses,
the
fate
and
transport
characteristics
of
PCNB
and
its
metabolites
are
indicative
of
a
potential
for
environmental
loading
that
increases
risks
substantially,
although
to
a
degree
that
cannot
be
quantified.

The
Agency
also
conducted
a
complete
benefits
assessment
for
the
major
uses
of
PCNB.
The
assessment,
captured
in
a
May
16,
2006
document,
is
described
in
this
Section.
The
Agency
has
developed
a
qualitative
analysis
of
benefits
for
the
minor
uses
of
PCNB.
The
Agency
acknowledges
that
for
these
uses,
more
complete
benefits
information
could
result
in
a
different
assessment
of
potential
benefits.
The
Agency
is
actively
soliciting
such
information
in
an
effort
to
­
60
­
­
gain
a
better
understanding
of
the
relationship
between
risks
and
benefits
for
those
uses.
The
minor
uses
for
which
the
Agency
seeks
such
information
and
the
particular
kinds
of
information
that
could
be
useful
in
refining
the
benefits
analysis
for
these
uses
are
detailed
in
this
Section.
It
is
possible
that
such
information,
provided
during
the
comment
period,
could
change
the
Agency's
understanding
of
the
risk/
benefit
relationship
for
specific
uses,
and
result
in
amendment
of
the
reregistration
eligibility
decisions
on
the
subject
uses.

All
of
the
assessment
documents
cited
in
this
RED
are
available
from
the
docket
at
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

This
RED
is
based
on
the
Agency's
current
understanding
of
the
risks
and
benefits
associated
with
PCNB
use.
For
uses
of
PCNB
which
are
not
eligible
for
reregistration,
the
Agency
has
made
a
determination
that
risks
outweigh
benefits.
The
rationale
for
the
determinations
on
the
different
uses
of
PCNB
is
detailed
in
this
Section.

b)
Summary
of
Mitigation
Measures
Proposed
by
Registrants
The
jointly
proposed
risk
mitigation
plan
submitted
by
Amvac
and
Chemtura
on
June
10,
2005
focused
mainly
on
reducing
dietary
and
worker
risk.
Measures
proposed
by
the
registrants
included:

°
Reduction
of
maximum
seasonal
application
rates
Peppers
(
from
20
to16.5
lb
ai/
A/
season)
Beans
(
from
2
to
1
lb
ai/
A/
season)
Peanuts
(
from
2
to
1
lb
ai/
A/
season)
Cotton
(
from
2
to
1.5
lb
ai/
A/
season)
Cole
crops
(
from
30
to
22.5
lb
ai/
A/
season).
°
Termination
of
garlic
use
°
Restriction
of
golf
course
use
to
tees,
greens,
and
fairways
°
Prohibition
of
some
application
methods
and
formulation
types,
including
all
aerial
applications
and
broadcast
applications
to
ornamental
bulbs
°
Additional
PPE
for
workers
(
For
peanuts,
risk
quotients
were
originally
assessed
at
a
rate
of
10
lb
ai/
A/
season.
The
2
lb
rate
represents
a
recent
intermediate
rate
reduction
originating
with
the
registrants.
For
the
cole
crops,
the
current
labeled
maximum
application
rate
of
30
lb
ai/
A/
season
was
the
basis
for
estimating
drinking
water
concentrations
and
the
environmental
concentrations
for
aquatic
organisms
in
the
original
assessment.
An
application
rate
of
22.5
lb
ai/
A/
season
was
modeled
to
calculate
risk
to
terrestrial
wildlife
in
the
original
assessment.)

The
registrants
later
proposed
to
terminate
all
turf
uses
of
PCNB
except
golf
course
tees,
greens,
and
fairways.
The
later
proposal
would
terminate
PCNB
use
on
residential
lawns;
industrial/
commercial
turf;
other
ornamental
turf
including
turf
in
school
yards,
parks,
playing
fields,
and
playgrounds;
sod
farms;
and
other
golf
course
areas.
­
61
­
­
c)
Human
Health
Risk
Mitigation
(
1)
Dietary
Risk
Mitigation
The
Agency
assessed
the
chronic
dietary
risks
from
drinking
water
that
would
be
associated
with
the
registrants'
complete
mitigation
proposal.
In
this
assessment,
the
Agency
used
an
alternate
adsorption
coefficient
for
the
turf
use
than
that
used
in
the
original
assessment,
based
on
a
technical
comment
from
the
registrants.
The
proposed
rate
reductions
and
termination
of
most
turf
uses
would
not
affect
estimates
of
food­
only
dietary
exposure
because
residues
estimated
on
food
were
mainly
based
on
field
trial
data
and
cannot
be
reliably
adjusted
for
different
application
rates,
and
turf
uses
do
not
result
in
residues
on
food.

The
registrants'
complete
mitigation
proposal
would
also
allow
the
Agency
to
incorporate
a
Golf
Course
Adjustment
Factor
(
GCAF)
into
the
dietary
and
ecological
water
exposure
assessments
to
represent
the
smaller
portion
of
golf
course
area
on
which
PCNB
could
be
used.
In
accordance
with
Agency
policy,
as
captured
in
"
Golf
Course
Adjustment
Factors
for
Simulated
Aquatic
Exposure
Concentrations,"
December
7,
2005,
the
proportion
of
golf
course
turf
that
is
tees,
greens,
and
fairways
has
been
estimated
at
34%.
The
Agency's
dietary
assessment
based
on
the
mitigation
proposed
by
the
registrants
was
also
revised
to
reflect
technical
refinements
needed
to
more
accurately
assess
the
contribution
of
PCNB
residues
in
animal
diets
and
animal
commodities.
The
use
of
the
GCAF
and
the
technical
refinements
together
resulted
in
decreased
estimates
of
dietary,
residential,
and
aggregate
risk
below
levels
of
concern.
(
The
GCAF
also
contributed
to
the
reduction
of
estimates
of
ecological
risk
associated
with
the
turf
use.)

Table
35
shows
the
modeled
surface
water
drinking
water
concentrations
that
would
be
associated
with
the
proposed
mitigation,
drawn
from
the
July
7,
2005
memo
entitled
"
Revised/
Refined
Tier
II
Aquatic
Exposure
Values
for
the
Drinking
Water
and
Ecological
Exposure
Assessments
of
PCNB
for
Use
During
Phase
6
 
Risk
Mitigation,"
for
potatoes
and
turf
only.
The
revised
values
for
cole
crops,
peanuts,
and
cotton
are
drawn
from
the
August
9,
2005
memo
entitled
"
Revised
Tier
II
Surface
Water
Exposure
Values
and
Terrestrial
Exposure
Values
for
PCNB
Based
on
Proposed
Lower
Application
Rates
(
Risk
Mitigation
Phase)."
Both
memos
are
posted
to
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

Table
35.
Estimated
Drinking
Water
Concentrations
Based
on
Proposed
Mitigation
Scenario
(
application
rate;
#
of
applications/
year)
Source
EDWCs
1­
in­
10
year
concentrations
(
used
to
assess
chronic
risk)

Turf
(
32.67
lb
ai/
A;
2)
12.2
ppb
Potato
(
25
lb
ai/
A;
1)
1.7
ppb
Cabbage
(
22.5
lb
ai/
A;
1)
Surface
water
10.3
ppb
­
62
­
­
Peanuts
(
1
lb
ai/
A;
1)
1.7
ppb
Cotton
(
1.5
lb
ai/
A;
1)
5.7
ppb
Although
the
cabbage
1­
in­
10
year
concentration
is
slightly
lower
than
the
turf
value,
the
Agency
determined
that
cabbage
concentration
was
a
more
reasonable
worst­
case
than
the
concentration
modeled
for
the
use
of
PCNB
on
golf
courses,
because
based
on
the
registrants'
proposal,
PCNB
use
on
golf
course
would
be
limited
to
tees,
greens,
and
fairways.
The
1­
in­
10
year
value
for
cabbage,
representing
cole
crops
in
general,
was
selected
for
use
in
the
revised
chronic
dietary
risk
assessment.
The
values
in
Table
35
can
be
compared
to
the
turf
value
in
Table
5,
which
was
used
to
assess
dietary
risk
from
PCNB
as
currently
registered.

Concurrent
with
the
assessment
of
the
risk
mitigation
proposal,
the
Agency
determined
that
residues
of
PCNB
and
metabolites
in
animal
food
items
(
especially
milk)
had
been
overestimated
in
part
because
the
theoretical
diet
of
lactating
cattle
contained
too
high
a
proportion
of
potato
culls.
Lactating
cattle
are
typically
fed
a
higher
proportion
of
grain,
rather
than
potatoes,
for
more
protein.
The
Agency
refined
the
theoretical
diet
to
more
closely
approximate
the
actual
diet
fed
to
lactating
cows.
In
addition,
the
Agency
looked
more
closely
at
how
PCNB
and
its
metabolites
are
likely
to
separate
into
aqueous
and
fat
components
of
animal
tissue
and
milk,
and
determined
that
the
metabolites
are
not
likely
to
appear
in
milk
to
the
degree
which
had
been
assumed
for
the
earlier
dietary
risk
assessments.
The
Agency
corrected
this
error.

Table
36
shows
the
revised
dietary
risk
estimates
for
food
alone
and
food
plus
water
that
would
be
associated
with
the
risk
mitigation
proposed
by
the
registrants
and
the
revisions
to
described
above.
These
results
are
discussed
more
thoroughly
in
the
memo
"
Pentachloronitrobenzene
(
PCNB).
Chronic
Dietary
Exposure
Assessments
for
the
Reregistration
Eligibility
Decision
(
RED),"
dated
October
20,
2005
and
posted
to
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

Table
36.
Chronic
Dietary
Risk
Estimates
Based
on
Proposed
Mitigation
and
Technical
Refinement/
Correction
of
the
Original
Assessment
Population
Subgroup
Risk
from
all
crops,
no
water,
%
cPAD
Risk
from
all
crops,
with
water,
%
cPAD
U.
S.
Population
12
33.4
All
infants
(<
1
yr)
8
79
Children
1­
2
yrs
34
66
Children
3­
5
yrs
25
55
Children
6­
12
yrs
16
36
­
63
­
­
Population
Subgroup
Risk
from
all
crops,
no
water,
%
cPAD
Risk
from
all
crops,
with
water,
%
cPAD
Youth
13­
19
yrs
10
26
Adults
20­
49
yrs
9
30
Adults
50+
yrs
10
32
Females
13­
49
yrs
9
29
For
the
general
population
and
all
subgroups,
the
dietary
risks
that
would
be
associated
with
the
proposed
mitigation
are
below
100%
of
the
cPAD.
The
values
in
Table
36
can
be
compared
to
those
in
Table
4,
which
represent
the
risks
based
on
PCNB
as
currently
labeled,
and
without
the
correction
and
refinement
made
to
the
original
assessment.
The
registrants'
proposal
would
be
adequate
to
reduce
the
dietary
risk
associated
with
the
use
of
PCNB
below
levels
of
concern.
Mitigation
required
by
this
RED
will
reduce
overall
usage
of
PCNB
and
is
likely
to
reduce
the
occurrence
and
magnitude
of
inadvertent
residues
in
crops
for
which
PCNB
is
not
registered.

(
2)
Residential
Risk
Mitigation
The
registrants
proposed
to
terminate
all
residential
turf
uses
of
PCNB,
so
residential
handler
and
post­
application
exposures
associated
with
those
uses
would
be
eliminated.
The
residential
risk
assessment
for
PCNB
focuses
on
turf,
the
predominant
residential
use
site
for
the
fungicide.
While
PCNB
is
also
used
on
broadleaf
ornamentals,
treatment
would
occur
most
typically
at
nurseries
and
other
production
facilities,
before
plants
are
purchased
for
placement
in
lawns
and
gardens.
Residential
use
on
non­
turf
ornamentals
is
limited,
but
based
on
the
very
high
risks
for
children
on
treated
turf
and
the
potential
for
residential
ornamental
applications
to
result
in
similar
exposures,
the
Agency
believes
that
PCNB
use
on
ornamentals
in
yards
and
gardens
may
pose
residential
post­
application
risk.
The
registrants'
proposal
does
not
adequately
address
residential
risk.
The
Agency
has
determined
that
the
use
of
PCNB
on
residential
ornamentals
is
not
eligible
for
reregistration.

(
3)
Golfer
Post­
Application
Risk
Mitigation
Risk
to
golfers
reentering
golf
course
areas
treated
with
PCNB
up
to
nine
days
previously
has
been
estimated
to
be
above
levels
of
concern.
The
results
of
this
initial
assessment
are
found
in
Table
7.
Since
this
initial
assessment
was
made,
an
ARTF
golf
course
maintenance
exposure
study
has
been
submitted
to
the
Agency,
and
the
Agency
believes
it
is
appropriate
to
use
data
from
that
study
to
refine
the
PCNB
post­
application
golfer
risk
estimates.
Review
of
information
(
in
the
form
of
transfer
coefficients
and
residues
on
turf)
from
that
study
indicates
that
the
golfer
reentry
risk
estimates
on
the
day
of
treatment
are
above
the
target
MOE
of
1000
(
3100­
4100),
and
therefore
not
of
concern.
These
results
are
discussed
more
thoroughly
in
the
memo
"
PCNB:
HED
Revision
of
Golfer
Risk
Assessment,"
dated
March
6,
2006
and
posted
to
­
64
­
­
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.
No
additional
risk
mitigation
is
needed
to
reduce
the
golfer
post­
application
risk
associated
with
the
use
of
PCNB.

(
4)
Aggregate
Risk
Mitigation
Under
the
registrants'
mitigation
proposal,
the
dietary
risk
estimates
associated
with
PCNB
use
would
fall
below
levels
of
concern,
and
residential
risk
associated
with
use
on
turf
would
be
eliminated.
Residential
risks
of
concern,
and
as
a
consequence,
aggregate
risks
of
concern,
would
still
be
associated
with
the
use
of
PCNB
on
ornamental
plants
around
the
home.
The
Agency
has
determined
that
the
aggregate
human
health
risks
from
exposures
to
PCNB
are
within
the
risk
cup
(
still
less
than
100%
of
the
cPAD)
only
when
the
exposures
associated
with
all
residential
uses
of
PCNB
are
eliminated.
The
Agency
has
determined
that
the
full
complement
of
residential
PCNB
uses,
including
the
use
on
ornamentals,
must
be
terminated
in
order
for
the
Agency
to
make
a
finding
that
tolerances
associated
with
the
use
of
PCNB
are
safe.

(
5)
Occupational
Handler
Risk
Mitigation
In
many
cases,
occupational
risks
of
concern
for
PCNB
would
be
adequately
reduced
by
the
use
of
PPE
as
proposed
by
the
registrants;
in
other
cases,
additional
PPE
is
needed.
Several
scenarios
are
associated
with
short­
and
intermediate 
term
MOEs
below
100
even
at
the
highest
applicable
levels
of
protections
afforded
by
PPE
and
engineering
controls.
These
scenarios
are
tabulated
below.
Scenario
numbers
are
provided
for
ease
of
reference
to
the
relevant
handler
risk
tables
(
Tables
10,
11,
and
13
above).

Table
37.
Risks
of
Concern
for
Handlers,
with
Maximum
PPE
and
Engineering
Controls
Exposure
Scenario
(
Number)
Comments
Mixer/
Loaders
(
Non­
seed
treatment)
dry
flowables/
chemigation/
sod
farms
(
6)
liquids/
chemigation/
sod
farms
(
16)
wettable
powders/
chemigation/
soil
banding
cole
crops
(
42)
wettable
powders/
chemigation/
sod
farms
(
50)
wettable
powders/
groundboom/
sod
farms
(
51)
Even
with
closed
systems,
MOEs
20­
89
Non­
seed
Applicators
(
Non­
seed
treatment)
dry
flowables
as
spray/
high­
pressure
handwand/
ornamentals
(
58)
emulsifiable
concentrates
/
high­
pressure
handwand/
industrial
lawn
(
65)
wettable
powders/
high­
pressure
handwand/
industrial
lawns
(
87)
Engineering
controls
for
applicators
(
enclosed
cab)
not
feasible
for
hand­
held
equipment;
even
with
most
protective
PPE
(
coveralls
+
chemical
resistant
gloves
+
air­
purifying
respirator),
MOEs
5.9­
59
Mixer/
loader/
applicators
or
loader/
applicators
(
Non­
seed
treatment)
liquids/
handgun
sprayer/
ornamentals
(
94)
Enclosed
cab
not
feasible
for
hand­
held
equipment;
with
most
protective
PPE
(
coveralls
+
chemical
resistant
gloves),
dermal
MOE
is
77
­
65
­
­
Exposure
Scenario
(
Number)
Comments
granules/
belly
grinder/
ornamentals
(
98)
Enclosed
cab
not
feasible
for
hand­
held
equipment;
no
data
available
to
assess
risk
if
coveralls
worn;
with
chemical
resistant
gloves,
dermal
MOE
is
21
granules/
push­
type
spreader/
ornamentals
(
99)
Enclosed
cab
not
feasible
for
hand­
held
equipment;
no
data
available
to
assess
risk
if
respirators
worn;
with
no
respirator,
inhalation
MOE
is
88
wettable
powders/
low­
pressure
handwand
ornamentals
(
100)
wettable
powders/
low­
pressure
handwand
shade
trees
(
101)
Engineering
controls
for
applicators
(
enclosed
cab,
closed
systems)
not
feasible
for
hand­
held
equipment;
even
with
most
protective
PPE
(
coveralls
+
chemical
resistant
gloves
+
airpurifying
respirator),
dermal
MOEs
3.1­
18,
inhalation
MOEs
0.58­
3.4
The
registrants
have
proposed
mitigation
measures
would
which
adequately
address
the
risks
for
most
of
the
scenarios
represented
in
Table
37.
These
measures
are:

°
Terminate
turf
uses
other
than
tees,
greens,
fairways
(
Scenarios
6,
16,
20,
89,
65,
87)
°
Prohibit
cole
crops
chemigation
(
42)
°
Prohibit
sod
farm
chemigation
(
50)
°
Prohibit
ground
boom
application
of
WP
formulation
to
sod
farms
(
51)
°
Prohibit
foliar
and
WP
applications
to
ornamentals
(
58,
94,
100,
101)
°
Prohibit
granular
application
by
belly­
grinder
to
ornamentals
(
98)

If
these
mitigation
measures
were
implemented,
occupational
risks
for
all
the
scenarios
shown
in
Table
37
would
be
eliminated,
except
for
Scenario
#
99,
applying
granules
with
a
pushtype
spreader
to
ornamentals.
The
formulation/
application
combination
for
this
use
poses
risks
that
the
Agency
addresses
in
labeling
requirements
detailed
in
Table
47
at
the
end
of
this
Section.

The
registrants
have
not
proposed
measures
to
address
risks
to
handlers
of
treated
seed,
but
respirators
are
required
to
address
risks
of
concern
for
these
workers.
PPE
and
other
label
requirements
to
address
worker
risks
are
detailed
in
Table
47.

(
6)
Occupational
Post­
application
Risk
Mitigation
Occupational
post­
application
risk
mitigation
for
PCNB
use
is
not
necessary
because
the
associated
risk
estimates
fall
well
below
levels
of
concern
even
on
the
day
of
treatment
(
Table
14).
d)
Ecological
Risk
Mitigation
The
Agency
recalculated
ecological
risk
quotients
based
on
the
full
complement
of
mitigation
measures
proposed
by
the
registrants.
The
revisions
based
on
the
mitigation
proposal
are
detailed
in
the
documents
"
Revised/
Refined
Tier
II
Aquatic
Exposure
Values
for
the
Drinking
Water
and
Ecological
Exposure
Assessments
of
PCNB
for
Use
During
Phase
6
 
Risk
­
66
­
­
Mitigation,"
July
07,
2005
(
for
turf
and
potatoes)
and
"
Revised
Tier
II
Surface
Water
Exposure
Values
and
Terrestrial
Exposure
Values
for
PCNB
Based
on
Proposed
Lower
Application
Rates
(
Risk
Mitigation
Phase),"
August
9,
2005
(
for
cabbage,
peanuts,
and
cotton).
Both
documents
are
available
at
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.

Environmental
loading
is
not
accounted
for
in
the
modeling
of
RQs
for
either
terrestrial
animals
or
aquatic
animals,
so
ecological
risk
is
underestimated.

Table
38
shows
the
EECs
that
would
be
associated
with
the
proposed
mitigation.

Table
38.
Surface
Water
Concentrations
Based
on
Proposed
Mitigation
Use
Site
(
Application
Parameters)
Peak
(
Acute
Assessment)
1­
in­
10
Year
21­
day
(
Fish
Chronic
Assessment)
1­
in­
10
Year
60­
day
(
Invertebrate
Chronic)
Cabbage
(
22.5
lb
ai/
A)
36.4
ppb
15.3
ppb
9.5
ppb
Cotton
(
1.5
lb
ai/
A)
12.3
ppb
6.4
ppb
4.8
ppb
Peanuts
(
1
lb
ai/
A)
8.2
ppb
3.1
ppb
1.9
ppb
Potato
(
22.5
lb
ai/
A)
7.7
ppb
2.5
ppb
1.3
ppb
Turf
(
32.67
lb
ai/
A,
2
applications)
33.9
ppb
12.1
ppb
7.5
ppb
The
values
in
Table
38
can
be
compared
to
the
values
in
Table
17,
which
were
used
to
estimate
RQs
for
PCNB
as
currently
registered.
The
values
in
Table
39
represent
what
the
RQs
would
be
if
the
proposed
mitigation
were
implemented.

(
1)
Aquatic
Risk
Quotients
Based
on
Proposed
Mitigaiton
Table
39.
Risk
Quotients
for
Aquatic
Animals
Based
on
Proposed
Mitigation
Use
Site
(
parameters
as
in
Table
38)
Freshwater
Acute
RQs
Estuarine/
Marine
Acute
RQs
Freshwater
Chronic
RQs
Fish
Invertebrate
Fish
Invertebrat
e
Fish
Invertebrate
Cabbage
0.36b
0.05
<
0.01
3.03a
0.73
0.85
Cotton
0.12b
0.02
<
0.01
1.03a
0.37
0.36
­
67
­
­
Use
Site
(
parameters
as
in
Table
38)
Freshwater
Acute
RQs
Estuarine/
Marine
Acute
RQs
Freshwater
Chronic
RQs
Fish
Invertebrate
Fish
Invertebrat
e
Fish
Invertebrate
Peanuts
0.08b
0.01
<
0.01
0.68a
0.15
0.17
Potato
0.08
b
0.01
<
0.01
0.64
a
0.1
0.14
Turf
0.34
b
0.04
<
0.01
2.8
a
0.58
0.67
a
exceeds
acute
level
of
concern
b
exceeds
acute
endangered
species
level
of
concern
RQs
from
Table
39
may
be
compared
to
the
RQs
in
Table
28
and
29,
which
represent
RQs
for
PCNB
as
currently
registered.
Although
aquatic
concentrations
would
decrease
based
on
the
proposed
rate
reductions,
acute
RQs
would
still
exceed
the
acute
high
risk
or
endangered
species
LOCs
for
freshwater
fish
and
estauarine/
marine
invertebrates
on
all
sites.
Without
chronic
toxicity
data
for
estuarine/
marine
animals,
chronic
risk
quotients
for
those
species
cannot
be
calculated.
Since
estuarine/
marine
invertebrates
are
more
sensitive
to
PCNB
on
an
acute
basis
than
their
freshwater
counterparts,
it
is
reasonable
to
assume
that
they
would
be
more
sensitive
on
a
chronic
basis
(
and
that
corresponding
RQs
would
likely
exceed
the
chronic
LOC
of
1.0).

(
2)
Terrestrial
Risk
Quotients
Based
on
Proposed
Mitigation
For
cabbage,
cotton,
and
peanuts,
RQs
for
terrestrial
wildlife
were
also
recalculated
based
on
the
registrant
proposal.
RQs
were
not
recalculated
for
potatoes
and
turf
because
the
registrants
did
not
propose
rate
reductions
for
these
sites,
and
the
GCAF
is
not
appropriate
for
application
to
terrestrial
wildlife.

The
Agency
based
its
initial
assessment
of
concentrations
of
PCNB
and
metabolites
on
food
sources
for
terrestrial
wildlife
on
the
ELL­
FATE
model.
Revisions
based
on
the
mitigation
proposal
(
found
in
the
August
9,
2005
document)
were
estimated
with
an
improved
version
of
that
model,
called
TREX,
which
accounts
for
different
diets
and
food
source
preferences
for
different
kinds
of
birds
and
mammals.
The
TREX
results
for
terrestrial
RQs
based
on
the
registrant
proposal
are
shown
in
Tables
40
and
41.
Table
40
shows
dose­
based
avian
acute
RQs,
and
Table
41
shows
dietary­
based
avian
chronic
RQs.
­
68
­
­
Table
40.
Avian
Acute
Dose­
based
RQs
Based
on
Proposed
Mitigation
Range
of
Acute
Avian
RQs
by
Body
weight
Use
Site
20
g
100
g
1000
g
Cabbage
<
0.02
to
<
0.31
<
0.05
to
<
0.88
<
0.25
to
<
3.9
Cotton
<
0.01
to
<
0.02
<
0.01
to
<
0.06
<
0.02
to
<
0.26
Peanuts
<
0.01
<
0.01
to
<
0.04
<
0.01
to
<
0.17
Table
41.
Avian
Chronic
Dietary­
based
RQs
Based
on
Proposed
Mitigation
Use
Site
Range
of
Chronic
Avian
RQs
Cabbage
0.56
to
9.0a
Peanuts
0.03
to
0.40
Cotton
0.04
to
0.60
a
exceeds
chronic
risk
level
of
concern
(
RQ
 
1.0)

The
terrestrial
assessment
for
PCNB
as
currently
registered
relied
on
ELL­
FATE
and
the
assessment
based
on
proposed
mitigation
relies
on
TREX,
so
direct
comparisons
between
RQs
are
not
appropriate.
PCNB
is
practically
nontoxic
to
birds
on
an
acute
basis,
and
the
Agency
considers
the
likelihood
of
avian
acute
mortality
to
be
low
for
all
of
the
modeled
uses.
The
proposed
mitigation
would
reduce
terrestrial
exposures,
but
some
avian
chronic
RQs
would
still
exceed
levels
of
concern.
When
the
impact
of
environmental
loading
is
factored
in,
chronic
risks
would
be
higher
than
those
represented
by
risk
quotients
alone.

Revised
risk
quotients
for
mammalian
wildlife
also
are
based
on
exposures
modeled
by
TREX.
Risk
quotients
are
shown
in
Table
42.

Table
42.
RQs
for
Mammals
Based
on
Proposed
Mitigation
Range
of
Acute
RQs
by
Body
Wt.
Range
of
Chronic
RQs
by
Body
Wt.

Use
Site
15
g
35
g
1000
g
15
g
35
1000
g
Cabbage
<
0.01
to
0.46
0.02
to
0.40
0.01
to
0.21
3.3
to
234a
2.8
to
200a
1.5
to
107a
Peanuts
<
0.01
to
0.02
<
0.01
to
0.02
<
0.01
to
0.01
0.14
to
10a
0.12
to
8.9a
0.07
to
4.8a
Cotton
<
0.01
to
0.03
<
0.01
to
0.03
<
0.01
to
0.01
0.22
to
16a
0.2
to
13a
0.10
to
7.2a
a
exceeds
chronic
risk
level
of
concern
(
RQ
 
1.0)
­
69
­
­
For
the
modeled
chronic
mammalian
RQs,
LOCs
are
exceeded
for
all
sizes
and
sites.
PCNB
is
practically
nontoxic
to
mammals
on
an
acute
basis,
and
the
Agency
considers
the
likelihood
of
mammalian
acute
mortality
to
be
low
for
all
of
the
modeled
uses.
e)
Synthesis
of
Risk
Ranking
from
RQs
and
Environmental
Loading
In
general,
the
mitigation
measures
proposed
by
the
registrants
would
be
reflected
in
somewhat
lower
RQs
for
aquatic
and
terrestrial
wildlife,
but
in
many
cases,
those
reductions
would
be
insufficient
to
address
concerns
for
non­
target
species.
In
addition,
the
fate
and
transport
characteristics
of
PCNB
and
its
metabolites
intensify
the
risk
to
non­
target
organisms.
The
overall
impact
of
the
fate
and
transport
characteristics
of
PCNB
on
the
RQs
cannot
be
quantified
and
thus
contributes
to
an
underestimation
of
ecological
risk
expressed
only
as
RQs.

The
combined
effect
of
the
fate
characteristics
on
the
amount
of
the
pesticide
and
its
metabolites
entering,
translocating,
and
remaining
in
the
environment
is
referred
to
in
this
document
as
"
environmental
loading."
Environmental
loading
varies
with
the
different
use
sites
for
a
pesticide,
and
is
a
function
of
how
much
of
the
pesticide
is
introduced
into
the
environment
and
remains
in
the
environment,
as
measured
by:

°
Usage
(
pounds
applied
on
an
annual
basis) 
a
measure
of
the
amount
of
PCNB
introduced
into
the
environment
as
a
whole
and
available
for
potential
exposures
to
wildlife
immediately
after
application;
and
the
amount
of
parent
and
metabolites
available
for
these
exposures
in
the
long­
term,
and
available
for
bioaccumulation
in
the
food
chain
and
long­
range
transport
to
other
ecosystems
and
species
outside
the
treatment
area
°
Percent
crop
treated
(
what
proportion
of
a
given
use
site
is
treated
in
a
year) 
a
measure
of
how
environmental
inputs
of
PCNB
are
distributed
within
areas
where
the
crop
is
grown,
suggestive
of
how
likely
wildlife
living
in
close
association
with
a
given
crop
are
to
be
exposed
to
harmful
levels
of
PCNB
and
its
metabolites
at
the
time
of
application
and,
through
the
persistent
nature
of
PCNB
and
its
metabolites,
in
the
long­
term
°
Application
rates 
reflect
the
concentration
of
toxic
material
present
on
individual
food
items
and
in
water
bodies
within
or
in
close
proximity
to
a
treated
area
at
the
time
of
application
and
during
the
time
it
takes
for
residues
to
dissipate
or
travel
off­
site.
Application
rates
are
a
factor
in
calculating
RQs,
unlike
usage
and
percent
crop
treated,
but
applied
material
not
consumed
or
otherwise
taken
up
by
non­
target
organisms
can
persist
in
the
environment,
and
is
available
for
long­
range
transport
or
other
off­
site
movement.

°
Application
methods­­
for
a
volatile
pesticide
like
PCNB,
a
foliar
application
may
result
in
more
volatilization
and
a
greater
potential
for
long­
range
transport.
In
contrast,
incorporated
treatments,
including
seed
treatments,
may
be
more
likely
to
result
in
persistent
residues
in
soil
or
water
bodies
near
the
area
of
application
or
contiguous
areas.

Usage,
percent
crop
treated,
and
application
rate
for
each
use
site
were
compared
to
the
range
of
values
for
all
the
use
sites,
and
identified
as
high­
end,
midrange­,
or
low­
end
within
the
range.
Distinctions
between
high­
end
and
midrange
and
between
midrange
and
low­
end
values
­
70
­
­
were
based,
where
possible,
on
natural
gaps
within
the
ranges.
Usage,
percent
crop
treated,
and
application
rates
were
categorized
as
in
Tables
43­
45,
with
use
sites
listed
from
high
to
low.

Table
43.
Domestic
Usage
of
PCNB
Use
site
and
Usage
Category
Annual
Usage,
lbs
ai
High­
end
Turf
(
tees,
greens,
and
fairways)
>
400,000
Cotton
400,000
Midrange
Potato
60,000
Green
beans
30,000
Cole
crops
23,000
Low­
end
Peanuts
5,000
Dry
beans
and
peas
2,000
Peppers
2,000
Others
<
500
Table
44.
Domestic
Percent
Crop
Treated
for
PCNB
Use
site
and
PCT
Category
Percent
Crop
Treated
High­
end
Green
beans
15­
20%
Midrange
Cotton
up
to
10%
Cole
crops
up
to
10%
Low­
end
Peppers
up
to
5%
(
New
Mexico
chile
peppers
reported
up
to
13%)
Potatoes
up
to
5%
Peanuts
<
2.5%
Dry
beans
and
peas
<
2.5%
Turf
(
tees,
greens,
and
fairways)
NA
Others
NA
NA
=
Information
not
available
­
71
­
­
Table
45.
Maximum
Application
Rates
for
PCNB
Use
site
and
Application
Rate
Category
Application
Rate,
lbs
ai/
A
High­
end
Turf
(
tees,
greens,
and
fairways)
32.67
(
twice/
season)
Cole
crops
22.5
Potato
22.5
Garlic
20.0
Peppers
16.5
Ornamentals
Variable
but
generally
high
Midrange
Tomato
7.0
Low­
end
Cotton
1.5
Green
beans
1.0
Peanuts
1.0
Dry
beans
and
peas
1.0
The
placement
of
individual
use
sites
within
the
ranges
for
usage,
percent
crop
treated,
and
application
rates,
with
consideration
of
the
application
method
(
foliar,
incorporated)
together
were
used
to
describe
the
environmental
loading
associated
with
each
use,
as
shown
in
Table
46.
­
72
­
­
Table
46.
Potential
Environmental
Loading
for
PCNB
Use
Sites
Use
Site
Usage
Category
PCT
Category
Application
Rate
Category
Notes
Environmental
Loading
Cole
Crops
Midrange
Midrange
High­
end
Medium
Tees,
greens,
and
fairways
High­
end
NA
High­
end
Foliar
application
High
Cotton
High­
end
Midrange
Low­
end
Medium
Potatoes
Midrange
Low­
end
High­
end
Some
"
over
the
top"
applications
High
Peanuts
Low­
end
Low­
end
Low
Seed
Treatments
NA
NA
Low­
end
Low
Green
Beans
Midrange
High­
end
Low­
end
Medium
Dry
beans,
peas
Low­
end
Low­
end
Low­
end
Low
Garlic
Low­
end
NA
High­
end
Medium
Tomatoes
Low­
end
Low­
end
Midrange
Low
Peppers
Chile
peppers
Low­
end
Midrange
High­
end
Up
to
13
PCT
in
NM
Medium
Other
peppers
Low­
end
Low­
end
High­
end
Medium
Ornamentals
Bulbs
Low­
end
NA
High­
end
Medium
Other
Low­
end
NA
High­
end
Medium
The
Agency
assigned
a
risk
ranking
to
each
PCNB
site
based
on
the
interplay
of
risk
quotients
(
where
available)
and
environmental
loading,
and
on
the
idea
that
risk
quotients
exceeding
levels
of
concern
are
the
starting
point,
and
that
environmental
loading
adds
to
the
risk
concerns
suggested
by
the
RQs.
The
magnitude
of
the
risk
quotients
also
plays
a
role.
Where
risk
has
not
been
quantitatively
assessed
as
risk
quotients,
the
risk
ranking
relies
on
measures
of
environmental
loading
alone.
The
risk
rankings
for
PCNB
use
sites
are
shown
in
Table
47.
Use
sites
represent
non­
seed
treatment
uses
unless
otherwise
noted.
­
73
­
­
Table
47.
Use­
specific
risk
characterization­­
RQs
and
environmental
loading
1,2
Use
site
Aquatic
Risk
Quotients
exceeding
LOCs
Terrestrial
Risk
Quotients
exceeding
LOCs
Environmental
loading
Risk
Ranking
Uses
for
which
RQs
have
been
calculated
Cole
crops
Acute
RQs:
FW
fish,
ES
0.36
FW
invertebrate,
ES
0.05
EM
invertebrate
3.0
Chronic
RQs:
Avian
up
to
9.0
Mammalian
up
to
234
Medium
High
Golf
course
tees,
greens,
and
fairways
Acute
RQs:
FW
fish,
ES
0.34
EM
invertebrate
2.8
Chronic
RQs:
Avian
up
to
33
Mammalian
up
to
1858
High
High
Cotton
Acute
RQs:
FW
fish,
ES
0.12
EM
invertebrate
1.0
Chronic
RQs:
Mammalian
RQs
up
to
16
Medium
Medium
Potatoes
Acute
RQs:
FW
fish,
ES
0.08
EM
invertebrate
0.64
Chronic
RQs:
Avian
up
to
6.6
Mammalian
up
to
375
High
High
Peanuts
Acute
RQs:
FW
fish,
ES
0.08
EM
invertebrate
0.68
Chronic
RQs:
Mammalian
RQs
up
to
10
Low
Medium
Seed
treatments
Chronic
LOCs
exceeded
for
all
seed
types;
Cotton
(
highest
RQ)
11;
assumes
diet
of
seeds
only
Low
Low
Uses
for
which
RQs
have
not
been
calculated
Green
beans
Medium
Medium
Dry
beans,
peas
Low
Low
Garlic
Medium
Medium
Tomatoes
Low
Low
Peppers
Medium
Medium
Ornamentals
(
commercial)
Medium
Medium
The
Agency
undertook
an
analysis
of
the
benefits
of
PCNB
use
in
order
to
examine
the
relationship
between
ecological
risks
and
benefits,
on
a
use­
by­
use
basis.

f)
Benefits
of
PCNB
Use
1
The
turf
and
potato
RQs
for
terrestrial
wildlife
based
on
ELL­
FATE
Version
1.4a;
all
others
based
on
T­
REX
Version
1.22
2
FW
=
freshwater;
E/
M
=
estuarine/
marine;
ES
=
endangered
species
­
74
­
­
The
May
22,
2006
document,
"
Benefits
and
Cost
Analysis
of
PCNB
and
Alternatives
for
Use
on
Golf
Course
Turf
(
Tees,
Greens,
Fairways),
Cotton,
Potatoes,
Green
Beans,
and
Cole
Crops
(
Cabbage,
Brussels
Sprouts,
Cauliflower),
the
Agency
examined
the
major
uses
of
PCNB
not
proposed
for
termination
by
the
registrants.
This
document
has
been
posted
on
the
PCNB
docket
and
may
be
accessed
at
http://
www.
regulations.
gov/
in
Docket
Number
OPP­
2004­
0202.
From
this
examination,
the
Agency
concluded
that,
with
the
exception
of
the
use
of
PCNB
on
cole
crops
for
clubroot,
all
the
major
uses
of
PCNB
are
associated
with
minimal
benefits,
because
the
target
pests
could
be
managed
with
comparable
efficacy
by
alternative
pesticides,
at
no
or
minimally
greater
cost.

The
Agency
has
not
quantitatively
assessed
benefits
for
the
minor
uses
of
PCNB.
For
these
uses,
the
Agency
made
assumptions
about
benefits
based
on
the
qualitative
assessment
of
public
comment,
comments
solicited
by
USDA
through
the
Regional
IPM
Centers,
Crop
Profiles
posted
at
http://
www.
ipmcenters.
org/
Crop
Profiles/,
anecdotal
information
about
how
users
value
PCNB,
and
usage
and
percent
crop
treated
information
as
indicators
of
benefits.
In
an
effort
to
better
understand
the
relationship
between
the
risks
and
benefits
of
these
minor
uses,
the
Agency
is
at
this
time
actively
soliciting
comments
relating
to
benefits,.
The
sites
for
which
the
Agency
is
soliciting
benefits
information
are:
dry
beans
and
peas,
peanuts,
tomatoes,
peppers
(
all
types),
and
ornamentals
in
commercial
production
(
all
types
except
for
flowering
bulbs).

Types
of
information
which
would
be
useful
in
this
regard
include
data
from
comparative
efficacy
trials
for
different
pesticides
used
to
control
diseases
on
these
sites,
information
about
the
relative
costs
of
using
PCNB
and
potential
alternatives,
production
cost
data,
information
on
why
registered
alternatives
are
not
appropriate
for
specific
diseases
in
a
particular
State
or
under
particular
climatic
conditions,
and
documentation
of
the
lack
of
alternatives
for
controlling
a
particular
disease.

The
Agency
ranked
the
benefits
(
assessed
or
assumed)
of
the
PCNB
uses
as
either
high
or
low,
to
represent
the
two
ends
of
a
spectrum.
These
rankings
are
shown
in
Table
48.
Use
sites
represent
non­
seed
treatment
uses
unless
otherwise
noted.
"
Uses
not
quantitatively
assessed
for
benefits"
do
not
include
turf
other
than
tees,
greens,
and
fairways,
or
garlic,
because
the
registrants
have
proposed
to
terminate
those
uses.
The
risk/
benefit
balance
for
uses
not
quantitatively
assessed
for
benefits
could
be
reconsidered
if
substantive
benefits
information
is
made
available
during
the
comment
period
after
release
of
this
RED.
It
is
possible
that
a
change
in
the
risk/
benefit
balance
for
any
of
these
uses
could
result
in
amendment
of
the
RED.
­
75
­
­
Table
48.
Benefits
characterization
of
uses
of
PCNB
Use
site
Usage,
percent
crop
treated
Other
benefits
information
Benefits
ranking
Uses
quantitatively
assessed
for
benefits
(
as
per
May
16,
2006
document)

Green
beans
30,000
lbs
ai/
yr,
15­
20%
crop
treated
Numerous
effective
and
economical
alternatives
for
both
target
diseases
Low
Cole
crops
23,000
lbs
ai/
yr,
up
to
10%
crop
treated
Several
effective
and
economical
alternatives
for
control
of
wirestem
For
wirestem,
Low
Lack
of
feasible
alternatives
for
control
of
clubroot
For
control
of
clubroot:
High
Golf
course
turf
(
tees,
greens,
and
fairways)
400,000+
lbs
ai/
yr
Numerous
highly
effective,
economically
feasible
alternatives
with
lesser
risk
of
phytotoxicity
Low
Cotton
400,000
lbs
ai/
yr,
up
to
10%
crop
treated
Several
alternatives
of
comparable
efficacy
and
cost
Low
Potatoes
60,000
lbs
ai/
yr,
up
to
5%
crop
treated.
Several
equally
effective
alternatives
of
comparable
cost
Low
Uses
not
quantitatively
assessed
for
benefits;
benefits
information
being
solicited
Turf
other
than
tees,
greens,
fairways
100,000
lbs
ai/
yr
(
approximate)
Benefits
for
tees,
greens,
and
benefits
represent
conservative
estimate
of
benefits
for
other
turf,
since
the
tolerance
for
disease
damage
on
tees,
greens,
and
fairways
is
very
low
relative
to
other
turf
sites
(
registrants
have
proposed
to
terminate)
Low
Dry
beans
and
peas
2,000
lbs
ai/
yr,
<
2.5%
crop
treated
Assumed
to
be
Low
benefit,
based
on
limited
use.
No
USDA
respondents
cited
use
as
critical.
Low
Peanuts
5,000
lbs
ai/
yr,
<
2.5%
crop
treated
Assumed
to
be
Low
benefit,
based
on
limited
usage.
USDA
respondent
in
TX
cited
extensive
use,
mainly
in
tank
mixes;
respondent
in
OK
cited
declining
use
Low
­
76
­
­
Use
site
Usage,
percent
crop
treated
Other
benefits
information
Benefits
ranking
Garlic
Limited
usage
Assumed
to
be
Low
benefit,
based
on
limited
usage
(
registrants
have
proposed
to
terminate)
Low
Tomatoes
Limited
usage
Assumed
to
be
Low
benefit
because
no
USDA
respondents
cited
use
as
critical.
Low
Peppers
2,000
lbs
ai/
yr,
up
to
5%
crop
treated
EPA
seeks
specific
information
on
benefits
to
all
types
of
peppers
NM
Crop
Profile
says
PCNB
used
on
13%
chile
pepper
acreage
Low
Other
peppers:
Only
USDA
respondent
to
mention
peppers
says
use
is
important
in
DE
Low
Ornamentals
in
commercial
production
Limited
usage
EPA
seeks
specific
information
on
benefits
to
all
types
of
ornamentals
in
commercial
production.
Anecdotal
information
suggests
PCNB
is
important
in
production
of
flowering
bulbs.
High
CA
Crop
Profile
indicates
29%
of
containerized
nurseries
use
PCNB
as
a
soil
drench,
numerous
alternatives
are
cited
Low
Seed
treatments
(
Application
rates
much
lower
than
rates
for
corresponding
soil
applications,
typically
<
10%)
Assumed
to
be
High
benefit,
based
on
input
of
USDA;
use
on
rice
and
safflower
seed
may
be
less
critical
High
4.
Determination
of
Eligibility
for
Reregistration
Based
on
the
assessment
of
human
health
risks
associated
with
the
PCNB
uses,
the
Agency
has
determined
that
post­
application
risks
associated
with
residential
and
related
uses
are
unacceptable.
These
uses
are
not
eligible
for
reregistration
because
the
Agency
cannot
make
a
determination
that
the
tolerance
reassessment
for
PCNB
meets
the
FQPA
safety
finding
based
on
the
contribution
of
these
uses
to
the
aggregate
risks
for
PCNB.
In
addition,
the
registrants
have
proposed
to
terminate
the
turf
uses
of
PCNB
other
than
golf
course
tees,
greens,
and
fairways.
The
following
uses
are
not
eligible
for
reregistration:
­
77
­
­
The
Agency
has
evaluated
the
relationship
of
risks
and
benefits
for
all
PCNB
uses
on
a
use­
by­
use
basis.
The
uses
of
PCNB
which
do
not
demonstrate
a
favorable
risk/
benefit
relationship
are
not
eligible
for
reregistration.
For
most
of
the
minor
uses
of
PCNB,
where
benefits
could
not
be
quantified,
the
Agency
believes
that
there
may
be
publicly­
held
information
on
benefits
that
could
affect
our
understanding
of
this
relationship,
and
the
reregistration
eligibility
decisions
for
these
uses.
The
Agency
has
solicited
information
that
could
better
inform
the
decisions
on
these
uses.

The
risk/
benefit
comparisons
and
the
reregistration
eligibility
decisions
for
all
the
uses
of
PCNB
for
which
these
comparisons
have
been
made
are
shown
in
Table
49.
Decisions
which
could
potentially
be
affected
by
the
submission
of
benefits
information
during
the
comment
period
following
the
release
of
the
RED
are
shown
in
italics.

Table
49.
Determinations
of
Reregistration
Eligibility
for
PCNB
uses
Use
Site
Risk/
Benefit
Eligibility
Green
beans
Medium/
Low
Not
eligible
Cole
crops
(
PCNB
is
used
to
control
two
different
diseases
of
cole
crops)

For
treatment
of
wirestem
High/
Low
Not
eligible
For
treatment
of
clubroot
High/
High
Eligible
Tees,
greens,
fairways
High/
Low
Not
eligible
Cotton
Medium/
Low
Not
eligible
Potatoes
High/
Low
Not
eligible
Turf
other
than
tees,
greens,
fairways*
High
/
Low
Not
eligible
Dry
beans/
peas
Low/
Low
Not
eligible
Garlic
Low/
Low
Not
eligible
Peanuts
Medium/
Low
Not
eligible
Tomatoes
Low/
Low
Not
eligible
Peppers
Chile
peppers
Medium/
Low
Not
eligible
Other
peppers
Medium/
Low
Not
eligible
Production
ornamentals
Flowering
bulbs
Medium/
High
Eligible
Other
ornamentals
Medium/
Low
Not
eligible
Seed
treatments
Low/
High
Eligible
*
Residential
turf
and
ornamentals,
and
turf
on
school
grounds,
and
in
parks,
playgrounds
­
78
­
­
The
uses
of
PCNB
with
risks
rated
higher
than
benefits
are
not
eligible
for
reregistration.
Uses
with
benefits
ranked
higher
than
risks
are
eligible
for
reregistration.

One
use
of
PCNB
appears
in
Table
49
with
both
high
risks
and
high
benefits.
Because
the
use
of
PCNB
to
control
clubroot
on
cole
crops
is
a
subset
of
the
overall
use
of
PCNB
on
cole
crops,
the
usage
and
percent
crop
treated
figures
cited
here
may
be
overstated.
The
Agency
believes
that
the
environmental
loading
associated
with
the
clubroot
use
is
probably
lower
than
that
associated
with
overall
use.
In
addition,
the
use
of
PCNB
on
cole
crops
when
applied
via
chemigation
poses
occupational
risks
that
cannot
be
adequately
mitigated
with
PPE
or
engineering
controls.
The
Agency
has
determined
that
the
use
of
PCNB
on
cole
crops,
if
labeled
for
control
of
clubroot
only,
and
to
prohibit
applicaton
via
chemigation,
is
eligible
for
reregistration.

Several
uses
of
PCNB
have
both
low
risks
and
low
benefits.
Because
the
ecological
risks
for
PCNB
are
assumed
to
be
underestimated,
due
to
the
significant
but
unquantified
impact
of
environmental
loading,
and
because
the
Agency
is
willing
to
consider
the
reregistration
decision
in
light
of
information
which
supports
greater
benefits
for
these
uses,
they
are
not
eligible
for
reregistration,
pending
consideration
of
such
information
submitted
during
the
comment
period
after
release
of
the
RED.

Based
on
the
risk­
benefit
comparisons,
and
the
other
considerations
discussed
above,
the
Agency
has
determined
that
the
following
uses
of
PCNB
are
not
eligible
for
reregistration:

°
green
beans
°
cole
crops
(
if
not
labeled
for
control
of
clubroot
only
and
to
prohibit
application
via
chemigation)
°
turf
°
cotton
°
potatoes
°
dry
beans
and
peas
°
garlic
°
peanuts
°
tomatoes
°
peppers
°
ornamentals
in
commercial
production
(
except
for
flowering
bulbs)
°
The
Agency
has
determined
that
the
following
uses
of
PCNB
are
eligible
for
reregistration:

°
cole
crops
(
labeled
for
control
of
clubroot
only
and
to
prohibit
application
via
chemigation)
°
flowering
bulbs
(
labeled
for
commercial
use
only)
°
seed
treatments
­
79
­
­
5.
Labeling
Requirements
In
order
to
be
eligible
for
reregistration,
all
products
containing
PCNB
must
bear
specific
use
and
safety
information
on
their
labeling.
In
addition,
certain
generic
and
product­
specific
data
will
be
required
for
PCNB
products.
The
specific
label
statements
and
a
list
of
outstanding
data
requirements
are
found
in
Section
V
of
this
RED
document.

6.
Endangered
Species
Considerations
Risk
Quotients
for
PCNB,
reflecting
mitigation
measures
proposed
by
the
registrants,
indicate
a
potential
for
acute
and
chronic
risks
to
listed
species
associated
with
the
modeled
use
sites,
as
noted
below:

Terrestrial
organisms
Mammals
°
Chronic
RQs
exceed
LOCs
for
cole
crops,
peanuts,
cotton,
and
potatoes
for
all
mammals
feeding
on
short
grass,
tall
grass,
and
broadleaf
plants
and
insects
°
Chronic
RQS
exceed
LOCs
for
turf
for
all
mammals
feeding
on
all
forage
items
Birds
(
reptiles,
terrestrial­
phase
amphibians)
°
Chronic
RQs
exceed
LOCs
for
cole
crops
and
potatoes
for
birds
feeding
on
short
grass,
tall
grass,
and
broadleaf
plants
and
insects
°
Chronic
RQs
exceed
LOCs
for
turf
for
birds
feeding
on
all
forage
items
°
Chronic
RQs
exceed
LOCs
for
seed­
eating
birds
for
all
modeled
seed
treatments
Seed
treatments
°
Chronic
RQs
exceed
LOCs
for
treated
seeds
of
barley,
cotton,
oats,
peas,
rice,
soybean,
and
sugar
beet
for
seed­
eating
birds
°
Chronic
RQs
exceed
LOCs
for
treated
seeds
of
all
types
for
seed­
eating
mammals
Aquatic
organisms
Freshwater
fish
(
aquatic­
phase
amphibians)
°
Acute
RQs
exceed
LOCs
for
all
sites
Freshwater
invertebrates
°
Acute
RQs
exceed
LOCs
for
cole
crops
Estuarine/
marine
invertebrates
°
Acute
RQs
exceed
LOCs
for
all
sites
Although
the
reregistration
decisions
for
PCNB
uses
will
eliminate
or
reduce
exposures
in
many
instances,
endangered
species
LOCs
associated
with
the
remaining
uses
of
PCNB
may
still
be
exceeded
for
aquatic
and
terrestrial
species.
­
80
­
­
To
address
concerns
about
risks
to
endangered
species
from
pesticide
use,
the
Agency
has
developed
the
Endangered
Species
Protection
Program
(
ESPP).
The
assessments
of
risk
for
aquatic
and
terrestrial
wildlife
described
in
this
RED
serve
as
a
screening
tool
to
determine
the
need
for
any
species­
specific
assessments
for
listed
species,
in
accordance
with
the
ESPP.
Such
assessments
would
refine
the
screening
level
assessment
by
taking
into
account
such
factors
as
the
geographic
areas
of
pesticide
use
in
relation
to
the
listed
species
and
the
habits
and
habitat
requirements
of
the
listed
species.
If
the
Agency's
species­
specific
assessments
result
in
the
need
to
modify
the
use
of
the
pesticide
in
specific
geographic
areas,
those
changes
will
be
undertaken
through
the
process
described
in
the
Agency
Federal
Register
Notice
(
54
FR
27984)
on
implementation
of
the
ESPP.

7.
Spray
Drift
Management
The
Agency
has
been
working
closely
with
stakeholders
to
develop
improved
approaches
for
mitigating
risks
to
human
health
and
the
environment
from
pesticide
spray
and
dust
drift.
As
part
of
the
reregistration
process,
we
will
continue
to
work
with
all
interested
parties
on
this
important
issue.
From
its
assessment
of
PCNB,
as
summarized
in
this
document,
the
Agency
concludes
that
certain
drift
mitigation
measures
are
needed
to
address
the
risks
from
off­
target
drift
for
PCNB.
Label
statements
implementing
these
measures
are
listed
in
Section
V
of
this
document.

V.
What
Registrants
Need
to
Do
The
Agency
has
determined
that
certain
uses
of
PCNB
are
eligible
for
reregistration
provided
that
the
risk
mitigation
measures
outlined
in
this
document
are
adopted,
and
label
amendments
are
made
to
reflect
those
measures.
To
implement
the
risk
mitigation
measures,
the
registrants
must
amend
their
product
labeling
to
incorporate
the
label
statements
set
forth
in
the
Label
Summary
Table
in
Section
D
below.
The
additional
data
requirements
that
the
Agency
intends
to
obtain
will
include,
among
other
things,
submission
of
the
following:

A.
Submissions
for
Technical­
Grade
Active
Ingredient
Products
1.
Within
90
Days
of
Receipt
of
the
Generic
DCI
For
each
PCNB
technical
grade
active
ingredient
product,
the
registrant
needs
to
submit
the
following
items
within
90
days
of
receiving
the
Generic
DCI:

°
completed
response
forms
to
the
generic
DCI
(
i.
e.,
DCI
response
form
and
requirements
status
and
registrant's
response
form);
°
submit
any
time
extension
and/
or
waiver
requests
with
a
full
written
justification);
and
°
compositional
analysis
of
registered
PCNB
technical
materials,
accounting
for
PCNB
and
all
contaminants
present
in
those
materials.
Materials
of
the
same
composition
must
be
used
to
develop
the
toxicity
data
required
by
the
DCI.

2.
Within
Generic
DCI
Deadlines
­
81
­
­
Within
the
time
limit
specified
in
the
generic
DCI,
the
registrant
must
cite
any
existing
generic
data
which
address
data
requirements
or
submit
new
generic
data
responding
to
the
DCI.
Please
contact
Jill
Bloom
at
(
703)
308­
8019
with
questions
regarding
generic
reregistration.

By
US
mail:
By
express
or
courier
service:
Document
Processing
Desk
(
DCI/
SRRD)
Document
Processing
Desk
(
DCI/
SRRD)
Jill
Bloom
Jill
Bloom
US
EPA
(
7508P)
Office
of
Pesticide
Programs
(
7508P)
1200
Pennsylvania
Ave.,
NW
4th
Floor,
One
Potomac
Yard
Washington,
DC
20460
2777
S.
Crystal
Dr.
Arlington,
VA
22202
B.
Submissions
for
End­
Use
Products
Containing
PCNB
1.
Within
90
Days
Within
90
days
from
the
receipt
of
the
product­
specific
data
call­
in
(
PDCI),
the
registrant
must
submit,
for
each
product:

°
completed
response
forms
to
the
PDCI
(
i.
e.,
PDCI
response
form
and
requirements
status
and
registrant's
response
form);
and
°
any
time
extension
or
waiver
requests
with
a
full
written
justification.

2.
Within
Product
DCI
Deadlines
Within
eight
months
from
the
receipt
of
the
PDCI,
the
registrant
must
submit:

°
two
copies
of
the
confidential
statement
of
formula
(
EPA
Form
8570­
4);
°
a
completed
original
application
for
reregistration
(
EPA
Form
8570­
1).
Indicate
on
the
form
that
it
is
an
"
application
for
reregistration";
°
five
copies
of
the
draft
label
incorporating
all
label
amendments
outlined
in
Table
47
of
this
document;
°
a
completed
form
certifying
compliance
with
data
compensation
requirements
(
EPA
Form
8570­
34);
and
°
if
applicable,
a
completed
form
certifying
compliance
with
cost
share
offer
requirements
(
EPA
Form
8570­
32);
and
°
the
product­
specific
data
responding
to
the
PDCI.

Please
contact
Bonnie
Adler
at
(
703)
308­
8523
with
questions
regarding
product
reregistration
and/
or
the
PDCI.
All
materials
submitted
in
response
to
the
PDCI
should
be
addressed
as
follows:

By
US
mail:
By
express
or
courier
service:
Document
Processing
Desk
(
PDCI/
PRB)
Document
Processing
Desk
(
PDCI/
PRB)
Bonnie
Adler
Bonnie
Adler
­
82
­
­
US
EPA
(
7508P)
Office
of
Pesticide
Programs
(
7508P)
1200
Pennsylvania
Ave.,
NW
4th
Floor,
One
Potomac
Yard.
Washington,
DC
20460
2777
S.
Crystal
Drive
Arlington,
VA
22202
C.
Manufacturing­
Use
Products 
Data
Requirements
and
Labeling
1.
Generic
Data
Requirements
Fulfillment
of
the
data
requirements
identified
in
the
risk
assessments
and
listed
below
is
necessary
to
confirm
the
reregistration
eligibility
decision
documented
in
this
RED.
The
Agency
will
consider
waiving
or
modifying
some
of
these
data
requirements
in
light
of
this
RED,
which
designates
most
uses
of
PCNB
as
ineligible
for
reregistration.

Table
50.
Generic
Data
Requirements
for
the
Reregistration
Eligibility
Decision
on
PCNB
Guideline
or
Special
Study
Name
or
Description
OPPTS
Guideline
No.

Direct
Photolysis
Rate
of
Parent
and
Degradates
in
Water
1
835.2240
Aerobic
Aquatic
Metabolism
Study2
835.4300
Anaerobic
Aquatic
Metabolism
Study2
835.4400
Invertebrate
Acute
Toxicity
Test,
Freshwater
Daphnids1
850.1010
Gammarid
Acute
Toxicity
Test1
850.1020
Estuarine/
marine
Mollusk
(
Oyster)
Acute
Toxicity
Test
(
Shell
Deposition)
1
850.1025
Estuarine/
marine
Mysid
(
Shrimp)
Acute
Toxicity
Test1
Special
Study
(
old
guideline
72­
3F)

Penaeid
Acute
Toxicity
Test1
850.1045
Bivalve
Acute
Toxicity
Test
(
Embryo
Larval)
1
850.1055
Fish
Acute
Toxicity
Test,
Freshwater
(
Bluegill
Sunfish)
1
850.1075
Fish
Acute
Toxicity
Test,
Rainbow
Trout
1
850.1075
Daphnid
Chronic
Toxicity
Test
(
early
life
stage
in
fish)
1
850.1300
Mysid
(
Shrimp)
Chronic
Toxicity
Test
(
life
cycle
in
aquatic
invertebrates 
estuarine/
marine
species)
(
parent
plus
PCA)
850.1350
Early­
life
Stage
Estuarine
Fish
(
parent
plus
PCA)
850.1450
Terrestrial
Plant
Toxicity,
Tier
1
(
Seedling
Emergence)
850.4100
­
83
­
­
Guideline
or
Special
Study
Name
or
Description
OPPTS
Guideline
No.

Terrestrial
Plant
Toxicity,
Tier
1
(
Vegetative
Vigor)
850.4150
Aquatic
Plant
Toxicity
Test
Using
Lemma
spp.
850.4400
Semi­
aquatic
Plant
Toxicity
Test
Special
Study
Foliar
Dissipation 
for
use
in
determining
potential
exposures
to
terrestrial
wildlife
(
not
dislodgeable
residues)
Special
Study
Radiolabeled
common
moiety
analytical
method
for
plants
and
animal
commodities,
as
discussed
in
Section
IV
of
this
RED
860.1340
Enforcement
analytical
method 
reserved
pending
approval
of
analytical
method
Special
Study
Magnitude
of
Residues
in
Meat,
Milk,
Poultry
and
Eggs­­
reserved
pending
approval
of
analytical
method
860.1480
Crop
Field
Trials
(
Magnitude
of
Residues
in
Plants) 
reserved
pending
approval
of
analytical
method
860.1500
Analytical
Reference
Standards 
reserved
pending
approval
of
analytical
method
860.1650
90­
day
Subchronic
Inhalation
Toxicity
Test,
Rat
3,
4
870.3465
Dermal
Absorption
(
Dermal
Penetration),
Rat
3,
5
870.7600
Iodide
Uptake,
Rat
Special
Study,
protocol
to
be
proposed
by
registrants
Comparative
Thyroid
Test
3,
6
Special
Study
Bioaccumulation
of
PCNB
and
metabolites;
determination
of
biological
half­
life
3,
7
Special
Study
Data
on
toxicological
significance
of
consistent,
dose
related
decreases
in
AST/
ALT
in
PCNB
toxicity
tests
3,
8
Special
Study
1
Test
material
is
PCA.
2
Soil
metabolism
studies
must
be
conducted
to
determine
conditions
which
favor
the
formation
of
pentachlorophenol
from
PCNB
and
to
track
the
production/
further
metabolism/
degradation
of
pentachlorophenol
over
time.
3
Since
small
differences
in
impurities
may
result
in
differences
in
the
toxicity
of
test
materials,
these
studies
must
be
conducted
with
materials
identical
to
marketed
technicals.
The
compositional
analysis
of
test
materials
for
each
study
must
be
verified
and
the
Agency
will
compare
this
documentation
to
the
compositional
analyses
of
each
technical
product
required
to
be
submitted
for
within
90
days
of
receipt
of
the
DCI,
as
noted
above.
4
In
addition
to
guideline
requirements,
interim
thyroid
hormone
analyses
required
at
7,
14,
30,
and
90
days.
Histopathology
assessment
to
include
thyroid
analysis.
5
Conditionally
required;
in
absence
of
data,
Agency
will
continue
to
assume
33%
dermal
absorption
by
default.
­
84
­
­
6
Registrants
must
submit
a
protocol
for
Agency
approval.
A
draft
protocol
has
been
developed
by
the
Agency
for
another
pesticide,
and
it
may
be
useful
as
a
basis
for
this
study.
Registrants
must
assess
thyroid
toxicity
in
adults
vs.
offspring.
For
already­
submitted
thyroid
metabolism
studies
(
MRIDs
440966­
01
and
440966­
02),
deficiencies
have
been
noted
in
reviews
and
must
be
addressed.
For
MRID
440966­
02,
raw
data
for
the
study
were
reported
as
missing
by
the
testing
facility
and
information
on
the
purity
and
lots
of
the
labeled
thyroxine
was
not
provided.
For
MRID
440966­
01,
registrant
must
submit
(
1)
data
on
the
fate
of
individual
animals
and
verification
of
the
number
of
treated
animals
that
died
prior
to
assignment
to
the
experimental
groups,
(
2)
clarification
of
the
different
compound
consumption
values
given
in
the
study
report,
and
(
3)
verification
that
the
test
diets
were
prepared
and
used
within
the
time
of
demonstrated
stability,
7
Submission
must
include
required
guideline
items
of
the
metabolism/
kinetics
study.
The
tier
II
level
study
must
be
performed.
Registrant
must
report
circulating
blood
levels
of
key
metabolites
and
PCNB
that
relate
to
key
end­
points
of
toxicity
and
dose
levels
in
other
studies;
dosing
regimen
based
on
thyroid
study
(
may
be
combined
with
comparative
thyroid
study
if
based
on
accepted
protocol).
8
Registrant
may
propose
to
submit
study
to
assess
toxicological
significance
of
these
findings,
or
may
propose
to
address
data
requirement
with
narrative
explanation.
The
AST/
ALT
finding
in
question
are
reported
in
MRIDs
43015801
(
rat),
and
41718600
and
41718601
(
dogs).

2.
Labeling
for
Manufacturing­
Use
Products
To
ensure
compliance
with
FIFRA,
manufacturing­
use
product
(
MUP)
labeling
should
be
revised
to
comply
with
all
current
EPA
regulations,
PR
Notices,
and
applicable
policies.
The
MUP
labeling
should
bear
the
labeling
contained
in
Table
47.

D.
End­
Use
Products 
Data
Requirements
and
Labeling
1.
Product­
Specific
Data
Requirements
Section
4(
g)(
2)(
B)
of
FIFRA
calls
for
the
Agency
to
obtain
any
needed
product­
specific
data
regarding
the
pesticide
after
a
determination
of
eligibility
has
been
made.
The
Registrant
must
review
previous
data
submissions
to
ensure
that
they
meet
current
EPA
acceptance
criteria
and
if
not,
commit
to
conduct
new
studies.
If
a
registrant
believes
that
previously
submitted
data
meet
current
testing
standards,
then
the
study
MRID
numbers
should
be
cited
according
to
the
instructions
in
the
Requirement
Status
and
Registrants
Response
Form
provided
for
each
product.
A
product­
specific
data
call­
in,
outlining
specific
data
requirements,
will
be
issued
separately
from
this
document.

2.
Labeling
for
End­
Use
Products
In
order
to
be
eligible
for
reregistration,
all
product
labels
must
be
amended
to
incorporate
the
risk
mitigation
measures
outlined
in
Section
IV.
Table
47
describes
how
language
on
the
labels
of
end­
use
products
should
be
amended.
­
85
­
­
E.
Existing
Stocks
Generally,
conditions
for
the
distribution
and
sale
of
products
bearing
old
labels/
labeling
will
be
established
when
the
label
changes
are
approved.
Specific
existing
stocks
time
frames
will
be
established
case­
by­
case,
depending
on
the
number
of
products
involved,
the
number
of
label
changes,
and
other
factors.

F.
Required
Labeling
Changes
In
order
to
be
eligible
for
reregistration,
all
product
labels
must
be
amended
to
incorporate
the
risk
mitigation
measures
outlined
in
Section
IV.
Table
51
details
how
language
on
the
labels
should
be
amended.
­
86
­
­

Table
51.
Labeling
Changes
for
Products
Containing
PCNB
Description
Amended
Labeling
Language
Placement
on
Label
Manufacturing­
Use
Products
For
All
Manufacturing­
Use
Products
"
This
product
may
be
formulated
into
a
fungicide
for
the
following
use(
s)
only:

soildirected
applications
for
treatment
of
clubroot
on
cole
crops;
soil­
directed
or
bulb­
soak
applications
for
commercial
production
of
flowering
bulb
plants
and
bulbs;
and
treatments
to
seeds
of
barley,
beans,
corn,
cotton,
oats,
peas,
peanut,
rice,
safflower,

sorghum,
soybeans,
sugar
beets,
and
wheat."

"
This
product
may
not
be
formulated
into
end­
use
products
labeled
for
use
on
cole
crops
(
unless
labeled
solely
for
treatment
of
clubroot),
turf
(
including
lawns),
green
beans
(
unless
labeled
solely
for
treatments
to
seeds),
cotton
(
unless
labeled
solely
for
treatments
to
seeds),
potatoes,
dry
beans
and
peas
(
unless
labeled
solely
for
treatments
to
seeds),
garlic,
peanuts
(
unless
labeled
solely
for
treatments
to
seeds),
tomatoes,
peppers,

or
ornamentals
(
except
commercial
production
of
flowering
bulb
plants
and
bulbs)."

"
This
product
may
not
be
formulated
into
end­
use
products,
unless
the
end­
use
products
are
labeled
to
prohibit
aerial
applications."

"
This
product
may
not
be
formulated
into
end­
use
products
with
directions
for
use
on
cole
crops,
unless
the
end­
use
products
are
labeled
to
prohibit
chemigation
applications
on
cole
crops."

"
This
product
may
not
be
formulated
into
end­
use
products
with
directions
for
use
for
commercial
production
of
flowering
bulb
plants
or
bulbs,
unless
the
end­
use
products
are
labeled
to
prohibit
applications
directed
at
foliage
or
flowers
and
to
prohibit
broadcast
applications."

"
This
product
may
be
formulated
into
wettable
powders
only
if
packaged
in
water­
soluble
packaging."

"
This
product
may
not
be
formulated
into
granular
products,
unless
these
products
are
labeled
to
prohibit
application
with
a
chest­
mounted
rotary
spreader
(
belly­
grinder)."
Directions
for
Use
­
87
­
­

Description
Amended
Labeling
Language
Placement
on
Label
"
This
product
may
be
formulated
into
dust
products
only
for
seed
treatment
applications."

"
This
product
may
not
be
formulated
into
end­
use
products
labeled
for
seed
treatment
uses,
unless
seed
treatments
are
the
sole
use
on
the
end­
use
product
labels."

"
This
product
may
not
be
formulated
into
end­
use
products
labeled
for
seed
treatment
uses,
unless
the
end­
use
products
are
labeled
to
incorporate
the
following
language:"

"
Seeds
that
have
been
treated
with
this
product
that
are
then
packaged
and
offered
for
sale
or
distribution
must
contain
the
following
labeling:"

"
This
bag
contains
seed
treated
with
PCNB.
To
avoid
possible
adverse
health
effects,

when
opening
this
bag
or
loading
the
treated
seed,
wear
long­
sleeved
shirt,
long
pants,

shoes
plus
socks,
chemical­
resistant
gloves,
and
a
NIOSH­
approved
respirator
equipped
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter.

"
Do
Not
Use
for
Food,
Feed,
or
Oil."

"
After
seeds
have
been
planted,
do
not
enter
or
allow
worker
entry
into
treated
areas
during
the
restricted­
entry
interval
(
REI)
of
12
hours.
Exception:
Once
seeds
are
planted
in
soil
or
other
planting
media,
the
Worker
Protection
Standard
allows
workers
to
enter
the
treated
area
without
restriction
if
there
will
be
no
worker
contact
with
the
soil/
media
subsurface."
­
88
­
­

Description
Amended
Labeling
Language
Placement
on
Label
One
of
these
statements
may
be
added
to
a
label
to
allow
reformulation
of
the
product
for
a
specific
use
or
all
additional
uses
supported
by
a
formulator
or
user
group
"
This
product
may
be
used
to
formulate
products
for
specific
use(
s)
not
listed
on
the
MP
label
if
the
formulator,
user
group,
or
grower
has
complied
with
U.
S.
EPA
submission
requirements
regarding
support
of
such
use(
s)."

"
This
product
may
be
used
to
formulate
products
for
any
additional
use(
s)
not
listed
on
the
MP
label
if
the
formulator,
user
group,
or
grower
has
complied
with
U.
S.
EPA
submission
requirements
regarding
support
of
such
use(
s)."
Directions
for
Use
Environmental
Hazards
Statements
Required
by
the
RED
and
Agency
Label
Policies
"
This
chemical
is
toxic
to
fish
and
aquatic
invertebrates.
Do
not
discharge
effluent
containing
this
product
into
lakes,
streams,
ponds,
estuaries,
oceans,
or
other
waters
unless
in
accordance
with
the
requirements
of
a
National
Pollution
Discharge
Elimination
System
(
NPDES)
permit
and
the
permitting
authority
has
been
notified
in
writing
prior
to
discharge.
Do
not
discharge
effluent
containing
this
product
to
sewer
systems
without
previously
notifying
the
local
sewage
treatment
plant
authority.
For
guidance
contact
your
State
Water
Board
or
Regional
Office
of
the
EPA."
Precautionary
Statements
­
89
­
­

End­
Use
Products
NOTE:
PPE
established
on
the
basis
of
Acute
Toxicity
of
the
end­
use
product
must
be
compared
to
the
active
ingredient
PPE
in
this
document.
The
more
protective
PPE
must
be
placed
in
the
product
labeling.
For
guidance
on
which
PPE
is
considered
more
protective,
see
PR
Notice
93­
7.

PPE
Requirements
Established
by
the
RED
for
Liquid,
Dry
Flowable,
or
Water
Dispersible
Granule
formulations
(
excludes
products
labeled
for
seed
treatment
use)

NOTE:
Products
labeled
for
nonseed
treatment
uses
must
not
be
labeled
for
seed
treatment
use
also.
NOTE:
When
cole
crops
are
not
listed
on
the
product
label,

references
to
this
use
may
be
removed
from
the
respirator
statement.

NOTE:
When
greenhouse
uses
or
bulb
soak
uses
are
prohibited
on
the
product
label,
references
to
the
corresponding
use(
s)
may
be
removed
from
the
respirator
statement.
"
Personal
Protective
Equipment
(
PPE)"

"
Some
materials
that
are
chemical­
resistant
to
this
product
are
(
registrant
inserts
correct
chemical­
resistant
material).
If
you
want
more
options,
follow
the
instructions
for
category
(
registrant
inserts
A,
B,
C,
D,
E,
F,
G,
or
H)
on
an
EPA
chemical­
resistance
category
selection
chart."

"
Mixers,
loaders,
applicators,
and
other
handlers
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,
except
for
applicators
using
groundboom
equipment,
and
chemical­
resistant
apron
when
involved
in
bulb
soak
applications.

In
addition,
all
1)
mixers
and
loaders,
2)
applicators
making
applications
to
cole
crops,
3)

applicators
performing
bulb
soak
applications,
and
4)
applicators
making
applications
in
greenhouses
must
wear
a
NIOSH­
approved
respirator
equipped
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter."

"
See
Engineering
Controls
for
more
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.
Immediately
following/
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
­
90
­
­

End­
Use
Products
PPE
Requirements
Established
by
the
RED
for
Wettable
Powder
formulations
(
excludes
products
labeled
for
seed
treatment
use)

NOTE:
Wettable
powder
formulations
must
be
packaged
in
water
soluble
packets.

NOTE:
Products
labeled
for
nonseed
treatment
uses
must
not
be
labeled
for
seed
treatment
use
also.

.
NOTE:
When
cole
crops
are
not
listed
on
the
product
label,

references
to
this
use
may
be
removed
from
the
respirator
statement.

NOTE:
When
greenhouse
uses
or
bulb
soak
uses
are
prohibited
on
the
product
label,
references
to
the
corresponding
use(
s)
may
be
removed
from
the
respirator
statement.
"
Personal
Protective
Equipment
(
PPE)"

"
Some
materials
that
are
chemical­
resistant
to
this
product
are
(
registrant
inserts
correct
chemical­
resistant
material).
If
you
want
more
options,
follow
the
instructions
for
category
(
registrant
inserts
A,
B,
C,
D,
E,
F,
G,
or
H)
on
an
EPA
chemical­
resistance
category
selection
chart."

"
Mixers,
loaders,
applicators,
and
other
handlers
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves
except
for
applicators
using
groundboom
equipment,

chemical­
resistant
apron
for
all
mixers
and
loaders
and
for
all
applicators
involved
in
bulb
soak
applications.

In
addition,
all
1)
applicators
making
applications
to
cole
crops,
2)
applicators
performing
bulb
soak
applications,
and
3)
applicators
making
applications
in
greenhouses
must
wear
a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter."

"
See
Engineering
Controls
for
more
requirements
and
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.
Immediately
following
or
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
­
91
­
­

End­
Use
Products
PPE
Requirements
Established
by
the
RED
for
Granular
Formulations
NOTE:
When
cole
crops
are
not
listed
on
the
product
label,

references
to
this
use
may
be
removed
from
the
respirator
statement.

NOTE:
When
greenhouse
uses
are
prohibited
on
the
product
label,
references
to
these
uses
may
be
removed
from
the
respirator
statement
.
"
Personal
Protective
Equipment
(
PPE)"

"
Loaders,
applicators,
and
other
handlers
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

In
addition,
all
1)
loaders,
2)
applicators
making
applications
to
cole
crops,
and
3)

applicators
making
applications
in
greenhouses
must
wear
a
NIOSH­
approved
respirator
equipped
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter."

"
See
Engineering
Controls
for
more
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.
Immediately
following/
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
PPE
Requirements
Established
by
the
RED
for
Dust
formulations
labeled
to
treat
seeds
NOTE:
Dust
formulations
are
limited
solely
to
seed
treatment
uses.
"
Personal
Protective
Equipment
(
PPE)"

"
Some
materials
that
are
chemical­
resistant
to
this
product
are
(
registrant
inserts
correct
chemical­
resistant
material).
If
you
want
more
options,
follow
the
instructions
for
category
(
registrant
inserts
A,
B,
C,
D,
E,
F,
G,
or
H)
on
an
EPA
chemical­
resistance
category
selection
chart."

"
All
loaders,
applicators,
handlers
involved
in
clean­
up
of
the
seed
treatment
area,
and
handlers
calibrating,
maintaining,
repairing,
or
cleaning
seed
treatment
equipment
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,

chemical­
resistant
apron
when
loading,
or
cleaning
spills
or
equipment,

a
NIOSH­
approved
half­
face,
full­
face
or
hood­
style
respirator
with
­­
a
dust/
mist
filtering
cartridge
(
MSHA/
NIOSH
approval
number
prefix
TC­
21C),
or
­­
a
canister
approved
for
pesticides
(
MSHA/
NIOSH
approval
number
prefix
TC­
14G),

or
Immediately
following/
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
­
92
­
­

End­
Use
Products
­­
a
cartridge
or
canister
with
any
N*,
R
or
P
or
He
filter.
A
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
not
permitted."

"
Persons
drying
or
bagging
treated
seed,
sewing
or
stacking
bags
containing
treated
seed,

or
operating
a
forklift
within
the
seed
treatment
area
are
handlers
and
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,
except
when
sewing
bags
of
treated
seed,

a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter.
A
NIOSH­
approved
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
one
type
of
respirator
which
is
permitted."

"
See
Engineering
Controls
for
more
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.

PPE
Requirements
Established
by
the
RED
for
Liquid,
Dry
Flowable,
and
Water
Dispersible
Granule
formulations
labeled
for
seed
treatment
use
NOTE:
Products
labeled
for
seed
treatment
uses
must
not
be
labeled
for
non­
seed
treatment
use
also.
"
Personal
Protective
Equipment
(
PPE)"

"
Some
materials
that
are
chemical­
resistant
to
this
product
are
(
registrant
inserts
correct
chemical­
resistant
material).
If
you
want
more
options,
follow
the
instructions
for
category
[
registrant
inserts
A,
B,
C,
D,
E,
F,
G,
or
H]
on
an
EPA
chemical­
resistance
category
selection
chart."

"
All
mixers,
loaders,
applicators,
and
handlers
involved
in
clean­
up
of
the
seed
treatment
area
and
all
handlers
calibrating,
maintaining,
repairing,
or
cleaning
seed
treatment
equipment
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,

chemical­
resistant
apron
when
mixing,
loading,
cleaning
up
spills
or
equipment,

a
NIOSH­
approved
half­
face,
full­
face
or
hood­
style
respirator
with
­­
a
dust/
mist
filtering
cartridge
(
MSHA/
NIOSH
approval
number
prefix
TC­
21C),
or
Immediately
following/
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
­
93
­
­

End­
Use
Products
­­
a
canister
approved
for
pesticides
(
MSHA/
NIOSH
approval
number
prefix
TC­
14G),

or
­­
a
cartridge
or
canister
with
any
N*,
R
or
P
or
He
filter.
A
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
not
permitted."

"
Persons
drying
or
bagging
treated
seed,
sewing
or
stacking
bags
containing
treated
seed,

or
operating
a
forklift
within
the
seed
treatment
area
are
handlers
and
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,
except
when
sewing
bags
of
treated
seed,

a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter.
A
NIOSH­
approved
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
one
type
of
respirator
which
is
permitted."

"
See
Engineering
Controls
for
more
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.

PPE
Requirements
Established
by
the
RED
for
Wettable
Powder
formulations
labeled
for
seed
treatment
use
NOTE:
Wettable
powder
formulations
must
be
packaged
in
water
soluble
packets.
"
Personal
Protective
Equipment
(
PPE)"

"
Some
materials
that
are
chemical­
resistant
to
this
product
are
(
registrant
inserts
correct
chemical­
resistant
material).
If
you
want
more
options,
follow
the
instructions
for
category
[
registrant
inserts
A,
B,
C,
D,
E,
F,
G,
or
H]
on
an
EPA
chemical­
resistance
category
selection
chart."

"
All
mixers,
loaders,
applicators,
and
handlers
involved
in
clean­
up
of
the
seed
treatment
area
and
all
handlers
calibrating,
maintaining,
repairing,
or
cleaning
seed
treatment
equipment
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,

chemical­
resistant
apron
when
mixing,
loading,
cleaning
up
spills
or
equipment,
­
94
­
­

End­
Use
Products
a
NIOSH­
approved
half­
face,
full­
face
or
hood­
style
respirator
with
­­
a
dust/
mist
filtering
cartridge
(
MSHA/
NIOSH
approval
number
prefix
TC­
21C),
or
­­
a
canister
approved
for
pesticides
(
MSHA/
NIOSH
approval
number
prefix
TC­
14G),

or
­­
a
cartridge
or
canister
with
any
N*,
R
or
P
or
He
filter.
A
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
not
permitted."

"
Persons
drying
or
bagging
treated
seed,
sewing
or
stacking
bags
containing
treated
seed,

or
operating
a
forklift
within
the
seed
treatment
area
are
handlers
and
must
wear:

long­
sleeved
shirts
and
long
pants,

shoes
plus
socks,

chemical­
resistant
gloves,
except
when
sewing
bags
of
treated
seed,

a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter.
A
NIOSH­
approved
quarter­
face
cup­
style
dust/
mist
filtering
respirator
is
one
type
of
respirator
which
is
permitted."

"
See
Engineering
Controls
for
more
options."

Instruction
to
Registrant:
Drop
the
"
N"
type
prefilter
from
the
respirator
statement,
if
the
pesticide
product
contains,
or
is
used
with,
oil.

User
Safety
Requirements
"
Follow
manufacturer's
instructions
for
cleaning/
maintaining
PPE.
If
no
such
instructions
for
washables
exist,
use
detergent
and
hot
water.
Keep
and
wash
PPE
separately
from
other
laundry."

"
Discard
clothing
and
other
absorbent
materials
that
have
been
drenched
or
heavily
contaminated
with
this
product's
concentrate.
Do
not
reuse
them."
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
immediately
following
the
PPE
requirements
Engineering
Controls
for
Liquid
Formulations
(
for
labels
where
the
use
patterns
make
the
use
of
an
enclosed
cab
feasible)
"
Engineering
Controls"

"
When
handlers
use
closed
systems
or
enclosed
cabs
in
a
manner
that
meets
the
requirements
listed
in
the
Worker
Protection
Standard
(
WPS)
for
agricultural
pesticides
(
40
CFR
170.240(
d)(
4,5),
the
handler
PPE
requirements
may
be
reduced
or
modified
as
Immediately
following
User
Safety
Requirements
­
95
­
­

End­
Use
Products
specified
in
the
WPS."

Engineering
Controls
for
Wettable
Powder
Formulations
"
Engineering
Controls"

"
Water­
soluble
packets
when
used
correctly
qualify
as
a
closed
mixing/
loading
system
under
the
Worker
Protection
Standard
for
Agricultural
Pesticides
[
40
CFR
170.240(
d)(
4)]."

"
Mixers
and
loaders
using
water­
soluble
packets
must
:

­­
wear
the
personal
protective
equipment
required
in
the
PPE
section
of
this
labeling
for
mixers
and
loaders,
and
­­
be
provided
and
must
have
immediately
available
for
use
in
an
emergency,
such
as
a
broken
package,
spill,
or
equipment
breakdown:
chemical­
resistant
footwear,
and
the
type
of
respirator
as
specified
in
the
PPE
section
of
this
label."

Include
this
statement
on
labels
where
the
use
patterns
make
the
use
of
an
enclosed
cab
feasible:

"
When
applicators
use
enclosed
cabs
in
a
manner
that
meets
the
requirements
listed
in
the
Worker
Protection
Standard
(
WPS)
for
agricultural
pesticides
(
40
CFR
170.240(
d)(
5),

the
handler
PPE
requirements
may
be
reduced
or
modified
as
specified
in
the
WPS."
Immediately
following
User
Safety
Requirements
Engineering
Controls
for
Granular,
Dry
Flowable,
and
Dry
Flowable
Formulations
(
for
labels
where
the
use
patterns
make
the
use
of
an
enclosed
cab
feasible)
"
Engineering
Controls"

"
If
applicators
use
enclosed
cabs
in
a
manner
that
meets
the
requirements
listed
in
the
Worker
Protection
Standard
(
WPS)
for
agricultural
pesticides
(
40
CFR
170.240(
d)(
5),

the
handler
PPE
requirements
may
be
reduced
or
modified
as
specified
in
the
WPS."
Immediately
following
User
Safety
Requirements
­
96
­
­

End­
Use
Products
Engineering
Controls
for
Dust
Formulations
Labeled
For
Seed
Treatments
"
Engineering
Controls"

"
If
loaders
and/
or
applicators
use
a
closed
system
designed
by
the
manufacturer
to
enclose
the
pesticide
to
prevent
it
from
contacting
handlers
or
other
people
while
it
is
being
handled
and
if
the
system
has
a
properly
functioning
dust
control
system
that
is
used
and
maintained
in
accordance
with
the
manufacturer's
written
operating
instructions,

handlers
using
the
closed
mixing/
loading
and/
or
application
system
must:

­­
wear
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
chemical­
resistant
gloves,

­­
be
provided,
have
immediately
available,
and
wear,
in
case
of
emergency,
such
as
a
broken
package
or
equipment
breakdown,
a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P
or
HE
filter."
Immediately
following
User
Safety
Requirements
Engineering
Controls
for
Liquid,

Dry
Flowable,
or
Water
Dispersible
Granule
Formulations
Labeled
for
Seed
Treatments
"
Engineering
Controls"

"
If
mixers/
loaders
or
applicators
use
a
closed
system
designed
by
the
manufacturer
to
enclose
the
pesticide
to
prevent
it
from
contacting
handlers
or
other
people
while
it
is
being
handled
and
if
the
system
has
a
properly
functioning
dust
control
system
that
is
used
and
maintained
in
accordance
with
the
manufacturer's
written
operating
instructions,

handlers
using
the
closed
mixing/
loading
and/
or
application
system
must:

­­
wear
long­
sleeve
shirt,
long
pants,
shoes,
socks,
chemical­
resistant
gloves,
and
chemical­
resistant
apron,

­­
be
provided,
have
immediately
available,
and
wear,
in
case
of
emergency,
such
as
a
broken
package
or
equipment
breakdown,
a
NIOSH­
approved
respirator
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P
or
HE
filter."
Immediately
following
User
Safety
Requirements
­
97
­
­

End­
Use
Products
User
Safety
Recommendations
"
User
Safety
Recommendations"

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

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

"
Users
should
remove
PPE
immediately
after
handling
this
product.
Wash
the
outside
of
gloves
before
removing.
As
soon
as
possible,
wash
thoroughly
and
change
into
clean
clothing."
Precautionary
Statements
under:

Hazards
to
Humans
and
Domestic
Animals
immediately
following
Engineering
Controls
(
Must
be
placed
in
a
box.)

Environmental
Hazard
Statement
"
This
pesticide
is
toxic
to
fish
and
aquatic
invertebrates.
Do
not
apply
directly
to
water,

to
areas
where
surface
water
is
present,
or
to
intertidal
areas
below
the
mean
high
water
mark
except
as
noted
on
appropriate
labels.
Drift
and
runoff
may
be
hazardous
to
aquatic
organisms
in
water
adjacent
to
treated
areas.
Do
not
contaminate
water
when
disposing
of
equipment
wash
waters
or
rinsate.
This
pesticide
is
toxic
to
birds
and
mammals.

Treated
seed
and
granules
on
soil
surface
may
be
hazardous
to
terrestrial
wildlife.
Cover
or
collect
any
such
materials
spilled
during
loading."
Precautionary
Statements
immediately
following
the
User
Safety
Recommendations
Restricted­
Entry
Interval
for
products
with
directions
for
use
within
scope
of
the
Worker
Protection
Standard
for
Agricultural
Pesticides
(
WPS)

(
excludes
products
with
directions
for
use
as
a
seed
treatment)
"
Do
not
enter
or
allow
worker
entry
into
treated
areas
during
the
restricted
entry
interval
(
REI)
of
12
hours.
Exception:
if
the
product
is
soil­
injected
or
soil­
incorporated,
the
Worker
Protection
Standard,
under
certain
circumstances,
allows
workers
to
enter
the
treated
areas
without
restriction
if
there
will
be
no
contact
with
anything
that
has
been
treated."
Directions
for
Use,

Under
Agricultural
Use
Requirements
Box
­
98
­
­

End­
Use
Products
Restricted­
Entry
Interval
for
products
with
directions
for
use
as
an
on­
farm,
planter
box,

hopper
box,
or
other
at­
plant
seed
treatment
"
Do
not
enter
or
allow
worker
entry
into
treated
areas
during
the
restricted
entry
interval
(
REI)
of
12
hours."
Exception:
Once
seeds
are
planted
in
soil
or
other
planting
media,

the
Worker
Protection
Standard
allows
workers
to
enter
the
treated
area
without
restriction
if
there
will
be
no
worker
contact
with
the
soil/
media
subsurface."
Directions
for
Use,

Under
Agricultural
Use
Requirements
Box
Early
Entry
Personal
Protective
Equipment
for
products
with
directions
for
use
within
the
scope
of
the
WPS
"
PPE
required
for
early
entry
to
treated
areas
that
is
permitted
under
the
Worker
Protection
Standard
and
that
involves
contact
with
anything
that
has
been
treated,
such
as
plants,
soil,
or
water,
is:

*
coveralls,

*
shoes
plus
socks
*
chemical­
resistant
gloves
made
of
any
waterproof
material"
Direction
for
Use
Agricultural
Use
Requirements
box
General
Application
Restrictions
"
Do
not
apply
this
product
in
a
way
that
will
contact
workers
or
other
persons,
either
directly
or
through
drift.
Only
protected
handlers
may
be
in
the
area
during
application."
Directions
for
Use
under
General
Precautions
and
Restrictions
­
99
­
­

End­
Use
Products
Other
Application
Restrictions
For
all
products:

"
Use
of
this
product
on
cole
crops
(
unless
labeled
solely
for
treatment
of
clubroot),
turf
(
including
lawns),
green
beans
(
unless
labeled
solely
for
treatments
to
seeds),
cotton
(
unless
labeled
solely
for
treatments
to
seeds),
potatoes,
dry
beans
and
peas
(
unless
labeled
solely
for
treatments
to
seeds),
garlic,
peanuts
(
unless
labeled
solely
for
treatments
to
seeds),
tomatoes,
peppers,
or
ornamentals
(
except
commercial
production
of
flowering
bulb
plants
and
bulbs)
is
prohibited."

For
all
products
for
which
aerial
application
is
feasible
(
e.
g.,
not
on
labels
containing
directions
solely
for
use
as
seed
treatment):

"
Aerial
applications
prohibited."

For
granular
formulations:

"
Application
with
a
chest­
mounted
rotary
spreader
(
belly­
grinder)
is
prohibited."

For
products
labeled
for
use
on
cole
crops:

"
Use
as
a
seed
treatment
is
prohibited."

For
products
labeled
for
use
on
ornamentals:

"
Use
as
a
seed
treatment
is
prohibited.
Use
on
ornamentals
is
limited
to
commercial
production
of
flowering
bulb
plants
or
bulbs
in
commercial
greenhouses,
nurseries,
or
field
production
facilities.
Use
in
residential
settings
is
prohibited.
Application
directed
at
foliage
or
flowers
is
prohibited.
Broadcast
applications
are
prohibited."

For
products
labeled
for
use
as
seed
treatment:

"
For
seed
treatment
applications
only.
Application
to
soil
or
foliage
is
prohibited."
Directions
for
Use
­
100
­
­

End­
Use
Products
Application
Restrictions
Associated
with
the
Directions
for
Use
on
Cole
Crops
NOTE:
Application
rates
must
be
listed
as
amounts
of
formulated
product.
"
Application
by
chemigation
to
cole
crops
is
prohibited.
This
product
may
only
be
used
for
treatment
of
clubroot.
Maximum
seasonal
application
rate
is
22.5
lb
ai/
A/
season
or
(
registrant
inserts
application
rate
as
amount
of
formulated
product
equivalent
to
22.5
lb
ai/
A/
season)."
Directions
for
Use
Application
restrictions
for
products
used
for
commercial
seed
treatments
This
product
may
not
be
used
to
treat
seed
unless
the
following
language
is
placed
on
the
pesticide
label:

"
Seeds
that
have
been
treated
with
this
product
that
are
then
packaged
and
offered
for
sale
or
distribution
must
contain
the
following
labeling:"

"
This
bag
contains
seed
treated
with
PCNB.
To
avoid
possible
adverse
health
effects,

when
opening
this
bag
or
loading
the
treated
seed,
wear
long­
sleeved
shirt,
long
pants,

shoes
plus
socks,
chemical­
resistant
gloves,
and
a
NIOSH­
approved
respirator
equipped
with:

­­
a
dust/
mist
filter
with
MSHA/
NIOSH
approval
number
prefix
TC­
21C
or
­­
any
N,
R,
P,
or
HE
filter."

"
Do
Not
Use
for
Food,
Feed,
or
Oil."

"
After
seeds
have
been
planted,
do
not
enter
or
allow
worker
entry
into
treated
areas
during
the
restricted­
entry
interval
(
REI)
of
12
hours.
Exception:
Once
seeds
are
planted
in
soil
or
other
planting
media,
the
Worker
Protection
Standard
allows
workers
to
enter
the
treated
area
without
restriction
if
there
will
be
no
worker
contact
with
the
soil/
media
subsurface."
Directions
for
Use
­
101
­
­

End­
Use
Products
Spray
Drift
"
SPRAY
DRIFT
MANAGEMENT"

"
Avoiding
spray
drift
at
the
application
site
is
the
responsibility
of
the
applicator
and
the
grower.
The
interactions
of
many
equipment
and
weather­
related
factors
determine
the
potential
for
spray
drift.
The
applicator
and
the
grower
are
responsible
for
considering
these
factors
when
making
decisions
about
spraying."

"
Apply
only
when
the
wind
speed
is
less
than
or
equal
to
10
mph
at
the
application
site."

"
Apply
as
a
medium
or
coarser
spray
(
ASAE
standard
527)."

"
Apply
using
a
nozzle
height
of
no
more
than
4
feet
above
the
ground
or
crop
canopy."
Directions
for
Use
­
102
­
­
Appendices
Appendix
A.
Table
of
Use
Patterns
Subject
to
Reregistration
Appendix
B.
Table
of
Generic
Data
Requirements
and
Studies
Used
to
Make
the
Reregistration
Decision
Appendix
C.
Citations
Considered
to
be
Part
of
the
Database
Supporting
Reregistration
Appendix
D.
Combined
Generic
and
Product­
Specific
Data
Call­
In
Attachment
1.
Chemical
Status
Sheets
Attachment
2.
Combined
Data
Call­
In
Response
Forms
Plus
Inserts
Attachment
3.
Generic
and
Product­
Specific
Requirement
Status
and
Registrant
Response
Forms
and
Instructions
Attachment
4.
End­
Use
Product
Batching
for
Reregistration
Data
Requirements
Attachment
5.
Registrants
Sent
this
Data
Call­
In
Notice
Attachment
6.
Cost
Share,
Data
Compensation
Forms,
Confidential
Statement
of
Formula
Form
and
Instructions
Appendix
E.
List
of
Available
Related
Documents
