UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
February
8,
2006
MEMORANDUM
SUBJECT:
Methyl
Bromide:
Tolerance
Revocation
of
Inorganic
Bromides.
PC
Code:
053201,
DP
Barcode:
D304618.

FROM:
Toiya
Goodlow,
Chemist
Reregistration
Branch
1
Health
Effects
Division
(
7509C)

THROUGH:
Michael
Metzger,
Branch
Chief
Reregistration
Branch
I
Health
Effects
Division
(
7509C)

TO:
Steven
Weiss,
Chemical
Review
Manager
Special
Review
and
Reregistration
Division
(
7508C)

The
Health
Effects
Division
has
received
a
request
from
the
Special
Review
and
Reregistration
Division
to
clarify
its
determination
to
classify
methyl
bromide
as
a
nonfood
use
pesticide
with
regard
to
its
soil
fumigant
uses,
to
establish
tolerances
based
only
on
the
parent
compound
for
commodity
fumigation
uses,
and
to
revoke
tolerances
for
inorganic
bromide.

Although
methyl
bromide
is
used
as
an
agricultural
pesticide,
it
is
considered
a
non­
food
use
chemical
for
soil
fumigation
uses
since
it
is
quickly
degraded
or
metabolized
in
the
soil,
and
subsequently
incorporated
into
natural
plant
constituents.
Residues
of
the
parent
compound
are
not
likely
to
be
found
in
foods
as
a
result
of
prior
treatment
of
fields.
While
residues
of
inorganic
bromide
may
be
present,
these
residues
are
indistinguishable
from
background
because
of
inorganic
bromide's
ubiquity
in
the
environment.
Therefore,
tolerances
are
not
required
for
soil
fumigant
uses
of
methyl
bromide,
and
tolerances
currently
established
for
residues
of
inorganic
bromide
resulting
from
methyl
bromide
soil
fumigation
(
40
CFR
180.199)
should
be
revoked.
Page
of
2
2
For
commodity
fumigation
uses,
residues
of
both
parent
methyl
bromide
and
inorganic
bromide
may
be
present.
Establishment
of
tolerances
for
methyl
bromide,
per
se,
allows
for
adequate
regulation
of
the
chemical
since
residues
of
the
parent
are
frequently
found
at
levels
above
the
limits
of
quantification.
HED
recommends
against
maintaining
current
tolerances
for
inorganic
bromide
(
40
CFR
180.123)
because
identifying
bromidefree
analytical
control
samples
may
not
be
possible
because
of
bromide's
ubiquity,
at
significant
levels,
in
the
environment;
these
tolerances
should
be
revoked
and
replaced
with
tolerances
for
methyl
bromide,
per
se,
as
described
in
the
review
by
Christine
Olinger
(
D271583,
2/
22/
02).
HED
does
not
consider
inorganic
bromide
to
be
of
risk
concern
at
the
levels
expected
in
foods
and
feeds.

7509C:
RRB1:
TGoodlow:
CM#
2:
Rm
722H:
308­
0070:
2/
8/
06
MMetzger:
2/
8/
06
