
United
States
Prevention,
Pesticides
EPA739­
R­
05­
003
Environmental
Protection
and
Toxic
Substances
August
2006
Agency
(
7510P)

Reregistration
Eligibility
Decision
for
2­(
Thiocyanomethylthio)­
benzothiazole
(
TCMTB)
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
CERTIFIED
MAIL
Dear
Registrant:

This
is
to
inform
you
that
the
Environmental
Protection
Agency
(
hereafter
referred
to
as
EPA
or
the
Agency)
has
completed
its
review
of
the
available
data
and
public
comments
received
related
to
the
preliminary
risk
assessments
for
the
antimicrobial
2­
(
thiocyanomethylthio)
benzothiazole
(
TCMTB).
The
Reregistration
Eligibility
Decision
(
RED)
for
TCMTB
was
approved
on
August
1,
2006.
Public
comments
and
additional
data
received
were
considered
in
this
decision.

Based
on
its
review,
EPA
is
now
publishing
its
Reregistration
Eligibility
Decision
(
RED)
and
risk
management
decision
for
TCMTB
and
its
associated
human
health
and
environmental
risks.
A
Notice
of
Availability
will
be
published
in
the
Federal
Register
announcing
the
publication
of
the
RED.

The
RED
and
supporting
risk
assessments
for
TCMTB
are
available
to
the
public
in
EPA's
Pesticide
Docket
EPA­
HQ­
OPP­
2006­
0320
at:
www.
regulations.
gov.

The
TCMTB
RED
was
developed
through
EPA's
public
participation
process,
published
in
the
Federal
Register
on
September
10,
2004,
which
provides
opportunities
for
public
involvement
in
the
Agency's
pesticide
tolerance
reassessment
and
reregistration
programs.
The
public
participation
process
encourages
robust
public
involvement
starting
early
and
continuing
throughout
the
pesticide
risk
assessment
and
risk
mitigation
decision
making
process.
The
public
participation
process
encompasses
full,
modified,
and
streamlined
versions
that
enable
the
Agency
to
tailor
the
level
of
review
to
the
level
of
refinement
of
the
risk
assessments,
as
well
as
to
the
amount
of
use,
risk,
public
concern,
and
complexity
associated
with
each
pesticide.
Using
the
public
participation
process,
EPA
is
attaining
its
strong
commitment
to
both
involve
the
public
and
meet
statutory
deadlines.

Please
note
that
the
TCMTB
risk
assessment
and
the
attached
RED
document
concern
only
this
particular
pesticide.
This
RED
presents
the
Agency's
conclusions
on
the
dietary,
drinking
water,
occupational
and
ecological
risks
posed
by
exposure
to
TCMTB
alone.
This
document
also
contains
both
generic
and
product­
specific
data
that
the
Agency
intends
to
require
in
Data
Call­
Ins
(
DCIs).
Note
that
DCIs,
with
all
pertinent
instructions,
will
be
sent
to
registrants
at
a
later
date.
Additionally,
for
product­
specific
DCIs,
the
first
set
of
required
responses
will
be
due
90
days
from
the
receipt
of
the
DCI
letter.
The
second
set
of
required
responses
will
be
due
eight
months
from
the
receipt
of
the
DCI
letter.
As
part
of
the
RED,
the
Agency
has
determined
that
TCMTB
will
be
eligible
for
reregistration
provided
that
all
the
conditions
identified
in
this
document
are
satisfied,
including
implementation
of
the
risk
mitigation
measure
outlined
in
Section
IV
of
the
document.
Sections
IV
and
V
of
this
RED
document
describe
the
labeling
amendments
for
end­
use
products
and
data
requirements
necessary
to
implement
this
mitigation
measure.
Instructions
for
registrants
on
submitting
the
revised
labeling
can
be
found
in
the
set
of
instructions
for
product­
specific
data
that
accompanies
this
document.

Should
a
registrant
fail
to
implement
any
of
the
risk
mitigation
measures
outlined
in
this
document,
the
Agency
will
continue
to
have
concerns
about
the
risks
posed
by
TCMTB.
Where
the
Agency
has
identified
any
unreasonable
adverse
effect
to
human
health
and
the
environment,
the
Agency
may
at
any
time
initiate
appropriate
regulatory
action
to
address
this
concern.
At
that
time,
any
affected
person(
s)
may
challenge
the
Agency's
action.

If
you
have
questions
on
this
document
or
the
label
changes
relevant
to
this
reregistration
decision,
please
contact
the
Chemical
Review
Manager,
K.
Avivah
Jakob,
at
(
703)
305­
1328.
For
questions
about
product
reregistration
and/
or
the
Product
DCI
that
will
follow
this
document,
please
contact
Marshall
Swindell
at
(
703)­
308­
6341.

Sincerely,

Frank
T.
Sanders
Director,
Antimicrobials
Division
REREGISTRATION
ELIGIBILITY
DECISION
for
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
List
B
CASE
2625
Approved
By:

Frank
T.
Sanders
Director,
Antimicrobials
Division
August
1,
2006
Attachment
Table
of
Contents
TCMTB
Reregistration
Team                   .......
i
Glossary
of
Terms
and
Abbreviations              ...   
ii
Abstract    ...                      .  ....
iv
I.
Introduction                           ..
1
II.
Chemical
Overview                       .
...
3
A.
Regulatory
History                    ..
...
3
B.
Chemical
Identification
                  ...
3
C.
Use
Profile                        ...
4
III.
Summary
of
TCMTB
Risk
Assessments               .
7
A.
Human
Health
Risk
Assessment               ...
7
1.
Toxicity
of
TCMTB
                 ....
7
2.
Metabolite
Assessment
                ...
12
3.
FQPA
Safety
Factor                  
13
4.
Population
Adjusted
Dose
(
PAD)            ...
14
a.
Acute
PAD                   
14
b.
Chronic
PAD                  
14
5.
Dietary
Exposure
Assumptions             
14
6.
Dietary
Risk
Assessment                .
15
a.
Dietary
Risk
from
Food
and
Drinking
Water    ..
15
b.
Dietary
Risk
from
Drinking
Water
        ..
17
7.
Residential
Risk
Assessment ...             
18
a.
Residential
Toxicity        ..   ..   .
18
b.
Residential
Handlers           ..
 .. ..
20
i.
Exposure
Assessment .
          .
20
ii.
Risk
Assessment       .  .    .
21
c.
Residential
Post­
Application ..          
21
i.
Exposure
Assessment .
          .
21
ii.
Risk
Assessment       .  .    .
22
8.
Aggregate
Risk                    .
23
a.
Acute
Aggregate
Risk          .   ...
24
b.
Chronic
Aggregate
Risk
           ... ..
24
9.
Occupational
Risk                  ...
25
a.
Occupational
Toxicity              .
26
b.
Occupational
Handler
Exposure          
26
c.
Occupational
Handler
Risk
Summary       ...
30
d.
Occupational
Post­
application
Risk
Summary    .
34
9.
Human
Incident
Data        ...        ...
37
B.
Environmental
Risk
Assessment               ..
38
1.
Environmental
Fate
and
Transport           ...
38
a.
Bioaccumulation
in
Aquatic
Organisms       
40
2.
Ecological
Risk                    .
40
a.
Environmental
Toxicity...            ...
40
b.
Ecological
Exposure
and
Risk
     .     .
44
c.
Risk
to
Listed
Species       .       .
47
IV.
Risk
Management,
Reregistration,
and
Tolerance
Reassessment
Decision 
49
A.
Determination
of
Reregistration
Eligibility           .
49
B.
Public
Comments
and
Responses               ..
49
C.
Regulatory
Position                     
50
1.
Food
Quality
Protection
Act
Findings          ...
50
a.
"
Risk
Cup"
Determination            .
50
b.
Determination
of
Safety
to
U.
S.
Population     ..
50
c.
Determination
of
Safety
to
Infants
and
Children   .
50
d.
Endocrine
Disruptor
Effects           ..
51
e.
Cumulative
Risks                .
52
2.
Tolerance
Summary                  
52
a.
Currently
Established
Tolerances
Under
40
CFR
180.288
&
Tolerance
Reassessment
of
TCMTB   ...
52
b.
Codex
Harmonization              .
53
D.
Regulatory
Rationale                    ..
53
1.
Human
Health
Risk
Management            .
54
a.
Dietary
(
Food)
Risk
Mitigation          ..
54
b.
Drinking
Water
Risk
Mitigation          
54
c.
Residential
Risk
Mitigation            
54
i.
Handler
Risk
Mitigation
          .
54
ii.
Post­
Application
Risk
Mitigation  .    .
54
d.
Occupational
Risk
Mitigation           
55
i.
Handler
Risk
Mitigation
          .
55
ii.
Post­
Application
Risk
Mitigation .     .
56
2.
Environmental
Risk
Management          ... ..
56
3.
Other
Labeling
Requirements              
57
4.
Listed
Species
Considerations          ..   ..
57
a.
The
Endangered
Species
Act  .         .
57
b.
General
Risk
Mitigation    ...        ..
58
V.
What
Registrants
Need
to
Do                    
60
A.
Manufacturing­
Use
Products                 
62
1.
Additional
Generic
Data
Requirements          
62
2.
Labeling
for
Technical
and
Manufacturing
Use
Products  ..
64
B.
End­
Use
Products                   ...  
64
1.
Additional
Product­
Specific
Data
Requirements    .........
64
2.
Labeling
for
End­
Use
Products             ..
64
a.
Label
Changes
Summary
Table          .
64
VI.
Appendices                           .
66
A.
Table
of
Use
Patterns
for
TCMTB
             . .
67
B.
Table
of
Generic
Data
Requirements
and
Studies
Used
to
Make
the
Reregistration
Decision              .....................
86
C.
Technical
Support
Documents                ..
94
D.
Bibliography
Citations                   ...
96
E.
Generic
Data
Call­
In                    ..
108
F.
Product
Specific
Data
Call­
In                 
109
G.
Batching
of
End­
Use
Products                ..
110
H.
List
of
All
Registrants
Sent
the
Data
Call­
In          ...
111
I.
List
of
Available
Forms                   ...
112
i
TCMTB
Reregistration
Team
Health
Effects
Risk
Assessment
Deborah
Smegal
Robert
Quick
Siroos
Mostaghimi
Jonathan
Chen
Charles
Smith
Samuel
Ary
Timothy
McMahon
Chris
Jiang
Ecological
Risk
Assessment
Kathryn
Montague
Environmental
Fate
Risk
Assessment
Srinivas
Gowda
James
Lin
Risk
Management
K.
Avivah
Jakob
Diane
Isbell
ii
GLOSSARY
OF
TERMS
AND
ABBREVIATIONS
a.
i.
Active
Ingredient
aPAD
Acute
Population
Adjusted
Dose
APHIS
Animal
and
Plant
Health
Inspection
Service
ARTF
Agricultural
Re­
entry
Task
Force
BCF
Bioconcentration
Factor
CDC
Centers
for
Disease
Control
CDPR
California
Department
of
Pesticide
Regulation
CFR
Code
of
Federal
Regulations
ChEI
Cholinesterase
Inhibition
CMBS
Carbamate
Market
Basket
Survey
cPAD
Chronic
Population
Adjusted
Dose
CSFII
USDA
Continuing
Surveys
for
Food
Intake
by
Individuals
CWS
Community
Water
System
DCI
Data
Call­
In
DEEM
Dietary
Exposure
Evaluation
Model
DL
Double
layer
clothing
{
i.
e.,
coveralls
over
SL}
DWLOC
Drinking
Water
Level
of
Comparison
EC
Emulsifiable
Concentrate
Formulation
EDSP
Endocrine
Disruptor
Screening
Program
EDSTAC
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee
EEC
Estimated
Environmental
Concentration.
The
estimated
pesticide
concentration
in
an
environment,
such
as
a
terrestrial
ecosystem.
EP
End­
Use
Product
EPA
U.
S.
Environmental
Protection
Agency
EXAMS
Tier
II
Surface
Water
Computer
Model
FDA
Food
and
Drug
Administration
FFDCA
Federal
Food,
Drug,
and
Cosmetic
Act
FIFRA
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
FOB
Functional
Observation
Battery
FQPA
Food
Quality
Protection
Act
FR
Federal
Register
GL
With
gloves
GPS
Global
Positioning
System
HIARC
Hazard
Identification
Assessment
Review
Committee
IDFS
Incident
Data
System
IGR
Insect
Growth
Regulator
IPM
Integrated
Pest
Management
RED
Reregistration
Eligibility
Decision
LADD
Lifetime
Average
Daily
Dose
LC50
Median
Lethal
Concentration.
Statistically
derived
concentration
of
a
substance
expected
to
cause
death
in
50%
of
test
animals,
usually
expressed
as
the
weight
of
substance
per
weight
or
volume
of
water,
air
or
feed,
e.
g.,
mg/
l,
mg/
kg
or
ppm.
LCO
Lawn
Care
Operator
LD50
Median
Lethal
Dose.
Statistically
derived
single
dose
causing
death
in
50%
of
the
test
animals
when
administered
by
the
route
indicated
(
oral,
dermal,
inhalation),
expressed
as
a
weight
of
substance
per
unit
weight
of
animal,
e.
g.,
mg/
kg.
LOAEC
Lowest
Observed
Adverse
Effect
Concentration
LOAEL
Lowest
Observed
Adverse
Effect
Level
LOC
Level
of
Concern
LOEC
Lowest
Observed
Effect
Concentration
mg/
kg/
day
Milligram
Per
Kilogram
Per
Day
MOE
Margin
of
Exposure
MP
Manufacturing­
Use
Product
MRID
Master
Record
Identification
(
number).
EPA's
system
of
recording
and
tracking
studies
submitted.
MRL
Maximum
Residue
Level
iii
N/
A
Not
Applicable
NASS
National
Agricultural
Statistical
Service
NAWQA
USGS
National
Water
Quality
Assessment
NG
No
Gloves
NMFS
National
Marine
Fisheries
Service
NOAEC
No
Observed
Adverse
Effect
Concentration
NOAEL
No
Observed
Adverse
Effect
Level
NPIC
National
Pesticide
Information
Center
NR
No
respirator
OP
Organophosphorus
OPP
EPA
Office
of
Pesticide
Programs
ORETF
Outdoor
Residential
Exposure
Task
Force
PAD
Population
Adjusted
Dose
PCA
Percent
Crop
Area
PDCI
Product
Specific
Data
Call­
In
PDP
USDA
Pesticide
Data
Program
PF10
Protection
factor
10
respirator
PF5
Protection
factor
5
respirator
PHED
Pesticide
Handler's
Exposure
Data
PHI
Pre­
harvest
Interval
ppb
Parts
Per
Billion
PPE
Personal
Protective
Equipment
PRZM
Pesticide
Root
Zone
Model
RBC
Red
Blood
Cell
RED
Reregistration
Eligibility
Decision
REI
Restricted
Entry
Interval
RfD
Reference
Dose
RPA
Reasonable
and
Prudent
Alternatives
RPM
Reasonable
and
Prudent
Measures
RQ
Risk
Quotient
RTU
(
Ready­
to­
use)
RUP
Restricted
Use
Pesticide
SCI­
GROW
Tier
I
Ground
Water
Computer
Model
SF
Safety
Factor
SL
Single
layer
clothing
SLN
Special
Local
Need
(
Registrations
Under
Section
24C
of
FIFRA)
STORET
Storage
and
Retrieval
TEP
Typical
End­
Use
Product
TGAI
Technical
Grade
Active
Ingredient
TRAC
Tolerance
Reassessment
Advisory
Committee
TTRS
Transferable
Turf
Residues
UF
Uncertainty
Factor
USDA
United
States
Department
of
Agriculture
USFWS
United
States
Fish
and
Wildlife
Service
USGS
United
States
Geological
Survey
WPS
Worker
Protection
Standard
iv
ABSTRACT
The
Environmental
Protection
Agency
(
EPA
or
the
Agency)
has
completed
the
human
health
and
environmental
risk
assessments
for
2­(
thiocyanomethylthio)
benzothiazole
(
TCMTB)
and
is
issuing
its
risk
management
decision
and
tolerance
reassessment.
The
risk
assessments,
which
are
summarized
below,
are
based
on
the
review
of
the
required
target
database
supporting
the
use
patterns
of
currently
registered
products
and
additional
information
received
through
the
public
docket.
After
considering
the
risks
identified
in
the
revised
risk
assessments,
comments
received,
and
mitigation
suggestions
from
interested
parties,
the
Agency
developed
its
risk
management
decision
for
uses
of
TCMTB
that
pose
risks
of
concern.
As
a
result
of
this
review,
EPA
has
determined
that
TCMTB­
containing
products
are
eligible
for
reregistration,
provided
that
risk
mitigation
measures
are
adopted
and
labels
are
amended
accordingly.
That
decision
is
discussed
fully
in
this
document.
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,
as
well
as
a
review
of
all
submitted
data
by
the
U.
S.
Environmental
Protection
Agency
(
EPA
or
the
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
of
1996
(
FQPA)
was
signed
into
law.
This
Act
amends
FIFRA
to
require
tolerance
reassessment.
The
Agency
has
decided
that,
for
those
chemicals
that
have
tolerances
and
are
undergoing
reregistration,
the
tolerance
reassessment
will
be
initiated
through
this
reregistration
process.
The
Act
also
requires
that
by
2006,
EPA
must
review
all
tolerances
in
effect
on
the
day
before
the
date
of
the
enactment
of
the
FQPA.
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.
This
document
presents
the
Agency's
revised
human
health
and
ecological
risk
assessments
and
the
Reregistration
Eligibility
Decision
(
RED)
for
2­(
thiocyanomethylthio)
benzothiazole
(
TCMTB).

As
an
antimicrobial
pesticide,
TCMTB
has
several
uses.
TCMTB
is
used
as
a
wood
preservative
for
antisapstain
control,
a
microbiocide/
microbiostat
and
bacteriocide/
bacteriostat
in
industrial
processes
and
water
systems
(
e.
g.,
pulp
and
paper
mill
systems,
sewage
systems)
and
in
industrial/
residential
materials
preservatives
(
e.
g.,
pulp/
paper
products,
leather
products
and
hides,
paint,
latex,
carpet,
textiles,
wallpaper).
TCMTB
is
also
used
as
an
agricultural
pesticide
for
seed
treatment
(
e.
g.,
barley,
oats,
rice,
wheat,
safflower,
cotton
and
sugar
beets).

The
Agency
has
concluded
that
the
FQPA
Safety
Factor
for
TCMTB
should
be
removed
(
equivalent
to
1X)
based
on:
(
1)
the
toxicology
data
base
is
complete
with
respect
to
assessing
the
increased
susceptibility
to
infants
and
children
as
required
by
FQPA
for
TCMTB;
(
2)
there
is
no
concern
for
developmental
neurotoxicity
resulting
from
exposure
to
TCMTB
in
the
rat
and
rabbit
prenatal
developmental
studies
and
2­
generation
reproduction
study;
(
3)
there
is
no
evidence
of
increased
susceptibility
to
the
fetus
following
in
utero
exposure
in
the
prenatal
developmental
toxicity
studies
or
to
the
offspring
when
adults
are
exposed
in
the
two­
generation
reproductive
study;
and
(
4)
the
risk
assessment
does
not
underestimate
the
potential
exposure
for
infants
and
children.

Risks
summarized
in
this
document
are
those
that
result
only
from
the
use
of
the
active
ingredient,
TCMTB.
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
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
2
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
TCMTB
and
any
other
substances.
TCMTB
does
not
appear
to
produce
a
toxic
metabolite
produced
by
other
substances.
For
the
purposes
of
this
action,
therefore,
EPA
has
not
assumed
that
TCMTB
has
a
common
mechanism
of
toxicity
with
other
substances.
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.

This
document
presents
the
Agency's
decision
regarding
the
reregistration
eligibility
of
the
registered
uses
of
TCMTB.
In
an
effort
to
simplify
the
RED,
the
information
presented
herein
is
summarized
from
more
detailed
information
which
can
be
found
in
the
technical
supporting
documents
for
TCMTB
referenced
in
this
RED.
The
revised
risk
assessments
and
related
addenda
are
not
included
in
this
document,
but
are
available
in
the
Public
Docket
at
http://
www.
regulations.
gov
(
Docket
ID
#
EPA­
HQ­
OPP­
2006­
0320).

This
document
consists
of
six
sections.
Section
I
is
the
introduction.
Section
II
provides
a
chemical
overview,
a
profile
of
the
use
and
usage
of
TCMTB
and
its
regulatory
history.
Section
III,
Summary
of
TCMTB
Risk
Assessments,
gives
an
overview
of
the
human
health
and
environmental
assessments,
based
on
the
data
available
to
the
Agency.
Section
IV,
Risk
Management,
Reregistration,
and
Tolerance
Reassessment
Decision,
presents
the
reregistration
eligibility
and
risk
management
decisions.
Section
V,
What
Registrants
Need
to
Do,
summarizes
the
necessary
label
changes
based
on
the
risk
mitigation
measures
outlined
in
Section
IV.
Finally,
the
Appendices
list
all
use
patterns
eligible
for
reregistration,
bibliographic
information,
related
documents
and
how
to
access
them,
and
Data
Call­
In
(
DCI)
information.
3
II.
Chemical
Overview
A.
Regulatory
History
TCMTB
was
first
registered
as
an
active
ingredient
by
the
United
States
Environmental
Protection
Agency
(
EPA)
on
January
21,
1980.
Currently,
there
are
27
products
containing
TCMTB.
TCMTB
products
are
used
in
commercial/
institutional
premises
and
residential
and
public
access
areas.
As
an
antimicrobial
pesticide,
TCMTB
is
used
largely
as
a
materials
preservative
(
e.
g.,
leather
products
and
hides,
pulp/
paper
products,
latex,
wallpaper,
paints,
carpets).
TCMTB
is
a
slimicide
regulated
by
the
FDA
(
21
CFR
176.300)
for
controlling
bacteria,
fungi
and
yeasts,
which
cause
deterioration
of
paper
and
paperboard
products.

TCMTB
is
also
used
as
a
fungicide
for
commercial
and
on­
farm
seed
treatment.
TCMTB
has
23
tolerances
in
the
40
CFR
180.288
for
use
as
a
fungicide
on
barley,
sugar
beets,
cotton,
oats,
rice,
safflower
and
wheat.
Seed
treatment
use
of
TCMTB
are
not
being
supported
by
the
technical
registrant
but
are
being
supported
by
end­
users.

B.
Chemical
Identification
Technical
TCMTB
N
S
S
S
N
Figure
1.
Molecular
Structure
of
TCMTB
Common
name:
TCMTB
or
TCMB
Chemical
name:
2­(
thiocyanomethylthio)
benzothiazole
Chemical
family:
Thiazole
Empirical
formula:
C9H6N2S3
CAS
Registry
No.:
21564­
17­
0
Case
number:
2625
OPP
Chemical
Code:
035603
Molecular
weight:
238
g/
mol
Other
names:
2­(
Benzothiazolythio)
methyl
thiocyanate,
TCMTB,
TCMB,
Busan
72
4
Basic
manufacturers:
Buckman
Laboratories
Chemical
properties:
TCMTB
is
a
vivid
orange
liquid
with
a
strong
sour
and
pungent
odor
(
like
mineral
oil).
TCMTB
is
a
liquid
and,
therefore,
has
no
melting
point.
It
has
a
boiling
point
of
1910C,
and
decomposition
begins
at
741.9
mm
Hg.
TCMTB
has
a
log
Kow
of
3.23
at
20oC.

C.
Use
Profile
The
following
information
is
a
description
of
the
currently
registered
uses
of
TCMTB
products
and
an
overview
of
use
sites
and
application
methods.
A
detailed
table
of
the
uses
of
TCMTB
eligible
for
reregistration
is
contained
in
Appendix
A.

Type
of
Pesticide:
Microbiocide/
microbiostat,
bacteriocide/
bacteriostat,
slimicide,
fungicide,
algecide.

Summary
of
Use:
Materials
Preservatives:
For
use
in
industrial
premises
and
residential
&
public
access
areas
as
a
materials
preservative
in
leather
processing
liquors/
extracts
(
preservative
incorporation),
leather
products
and
hides
(
preservative
incorporation),
textiles/
fibers/
cordage
(
preservative/
additive
incorporation),
paints,
sealants,
emulsions/
slurries/
solutions,
adhesives
(
preservative
incorporation),
coatings
(
preservative
incorporation),
,
metalworking
cutting
fluids
(
preservative
incorporation),
oil
recovery
drill
muds/
packer
fluids
(
preservative
incorporation),
nonfood
pulp/
paper
and
paper
products
(
preservative/
additive
incorporation),
wet­
end/
industrial
process
chemicals
(
preservative
incorporation),
caulking
compounds,
vinyl
wallpaper
pastes,
latex,
dispersed
colors,
fuels
(
additive
incorporation)
and
paper/
paperboard
surface
treatments.

Wood
Preservative:
TCMTB
is
used
to
control
sapstain
and
mold
in
commercial/
industrial
premises
and
residential
&
public
access
areas
on
forest
products
(
seasoned,
unseasoned,
unpainted),
lumber,
poles/
posts,
timbers,
wood
walls,
wood
(
particleboard),
wood
shingles
(
roof),
wood
pressure
treatment,
wood
millwork,
wood
products,
wood
sashes,
wet
lap/
sheet
pulp,
wood
surfaces,
wood
porches/
decks,
wood
fences,
wood
homes/
houses,
wood
steps,
window
frames,
wood
doors,
wood
siding
and
wood
barns.

Industrial
Processes
and
Water
Systems:
For
use
in
commercial
and
industrial
water
cooling
tower
systems,
pulp
and
paper
mill
systems,
secondary
oil
recovery
injection
water,
sewage
5
systems,
non­
potable
water
storage
tanks,
fuel
and
oil
storage
tanks
bottom
water,
industrial
disposal
water,
waste
water
systems,
sewage
effluent
water,
storage
tanks,
metalworking
cutting
fluids
and
water­
based
cutting
fluid
mixes.

Agricultural:
TCMTB
is
used
as
a
fungicide
for
treating
seeds
(
barley,
oats,
rice,
wheat,
safflower,
cotton
and
sugar
beets)
in
commercial
and
on­
farm
settings.

Target
Pests:
Bacteria
(
unspecified);
bacterial
blight
(
xanthomonas);
bacterial
slime
(
of
paper
mills,
water
systems);
basal
rot
(
fusarium);
brown
rot;
bunt
(
smut)
(
tilletia);
covered
kernel
smut
(
sphacelotheca);
covered
smut
(
ustilago
kolleri/
ustilago);
damping­
off
(
fusarium/
pythium/
rhizoctonia/
thielviopsis),
deterioration/
spoilage
bacteria;
dry
rot;
dry
rot
fungi;
false
loose
smut
(
ustilago
avenae/
u.
nigra);
fungal
decay/
rot;
fungal
slime
(
of
paper
mills/
water
systems);
fungi
(
coatings/
leather/
metal
working
coolants);
fusarium
blight;
rot/
SPP;
helminthosporium
blight;
mildew/
mold;
rhizopus;
rust
(
puccinia);
sapstain;
scab
(
head
blight);
seed
and
seedling
diseases/
decay/
rot/
fungi;
slime
forming
bacteria;
sulfatereducing
bacteria.

Formulation
Types:
Liquid
ready­
to­
use,
soluble
concentrate,
emulsifiable
liquid,
suspendedemulsion
formulation
intermediate,
wettable
powder.

Method
and
Rates
of
Application:

Equipment
for
Antimicrobial
Use:

TCMTB
end
use
products
are
added
during
the
manufacturing
process
of
treated
articles
and
materials.
Examples
include:
TCMTB
being
added
directly
to
pulp
slurry
by
chemical
metering
pump;
dipping/
pressure
impregnation
or
brush/
low
pressure
spraying
of
TCMTB
for
sapstain
control;
TCMTB
directly
mixed
into
solution
for
leather
preservation.

Equipment
for
Agricultural
Use:
There
are
two
primary
methods
for
treating
seeds:
the
batch
system
and
the
continuous
flow
system.
There
are
various
pieces
of
equipment
used
for
on­
nursery
seed
treatment
such
as
drum
mixers,
other
devices
using
augers,
cement
mixers,
hand
cranked
revolving
drums,
and
gravity
feed
systems.
TCMTB
treated
seed
can
be
planted
with
a
wide
range
of
equipment.
6
Application
Rates:
For
details
about
specific
use
sites
for
TCMTB,
refer
to
Appendix
A.

 
Dosage
rates
of
0.025­
0.2%
(
250­
2,000
ppm)
TCMTB
solution
can
be
used
during
various
stages
of
leather
processing.
 
Application
rates
can
range
from
0.026
lbs
ai/
100
lbs
seed
to
0.093
lbs
ai/
100
lbs
of
seed
for
seed
treatment.
 
Application
rates
can
range
from
5.6
to
44.0
kg
antisapstain
product/
100
L.
of
water
for
antisapstain
treatment.

Use
Classification:
General
use.
7
III.
Summary
of
TCMTB
Risk
Assessments
The
purpose
of
this
summary
is
to
assist
the
reader
by
identifying
the
key
features
and
findings
of
these
risk
assessments
and
to
help
the
reader
better
understand
the
conclusions
reached
in
the
assessments.
The
human
health
and
ecological
risk
assessment
documents
and
supporting
information
listed
in
Appendix
C
were
used
to
formulate
the
safety
finding
and
regulatory
decision
for
TCMTB.
While
the
risk
assessments
and
related
addenda
are
not
included
in
this
document,
they
are
available
from
the
OPP
Public
Docket
EPA­
HQ­
OPP­
2006­
0320,
and
may
also
be
accessed
from
www.
regulations.
gov.
Hard
copies
of
these
documents
may
be
found
in
the
OPP
public
docket.
The
OPP
public
docket
is
located
in
Room
S­
4900,
One
Potomac
Yard,
2777
South
Crystal
Drive,
Arlington,
VA
22202,
and
is
open
Monday
through
Friday,
excluding
Federal
holidays,
from
8:
30
a.
m.
to
4:
00
p.
m.

The
Agency's
use
of
human
studies
in
the
TCMTB
risk
assessment
is
in
accordance
with
the
Agency's
Final
Rule
promulgated
on
January
26,
2006,
related
to
Protections
for
Subjects
in
Human
Research,
which
is
codified
in
40
CFR
Part
26.

A.
Human
Health
Risk
Assessment
1.
Toxicity
of
TCMTB
A
brief
overview
of
the
toxicity
studies
used
for
determining
endpoints
in
the
risk
assessment
is
outlined
below
in
Table
1.
Further
details
on
the
toxicity
of
TCMTB
can
be
found
in
the
"
Toxicology
Disciplinary
Chapter
for
the
Reregistration
Eligibility
Decision
(
RED)
Risk
Assessment,"
dated
April
4,
2006;
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
August
1,
2006;
and
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)­
Report
of
the
Antimicrobials
Division
Toxicity
Endpoint
Selection
Committee
(
ADTC),"
dated
April
19,
2006.
These
documents
are
available
on
the
Agency's
website
in
the
EPA
Docket
at:
http://
www.
regulations.
gov
(
Docket
ID
#
EPA­
HQ­
OPP­
2006­
0320).

The
Agency
has
reviewed
all
toxicity
studies
submitted
for
TCMTB
and
has
determined
that
the
toxicological
database
is
sufficient
for
reregistration.
The
studies
have
been
submitted
to
support
guideline
requirements.

Major
features
of
the
toxicology
profile
are
presented
below.
TCMTB
exhibits
low
acute
oral
and
dermal
toxicity
(
toxicity
category
III).
However,
it
is
highly
irritating
to
the
eyes
and
skin
(
toxicity
category
I
and
II,
respectively)
and
is
also
considered
to
be
highly
toxic
via
the
inhalation
route
of
exposure
(
toxicity
category
I).
TCMTB
is
a
dermal
sensitizer.
8
Table
1.
Summary
of
Acute
Toxicity
Data
for
TCMTB
Guideline
No.
Study
Type
MRID
#(
s)
Results
Toxicity
Category
Acute
Toxicity
870.1100
Acute
oral
toxicity
41583801
LD50
=
750
mg/
kg
(
M+
F);
80%
ai
III
870.1200
Acute
dermal
toxicity
41515401
LD50
>
2000
mg/
kg
(
M+
F);
80%
ai
III
870.1300
Acute
inhalation
toxicity
41640601
LC50=
0.07
mg/
L;
80%
ai
I
870.2400
Acute
eye
irritation
Acc
No.
111991
Diluted
Busan
72
(
60
%
ai):
Primary
Irritation
Score
(
PIS)=
2/
110
(
slight
conjunctival
redness,
no
corneal
opacity);
Undiluted
Busan
72
(
60%
ai)
PIS=
34/
110
(
blanched
conjunctivae,
chemosis,
corneal
opacity
not
reversible
by
day
7)
I
870.2500
Acute
dermal
irritation
41583701
Primary
Irritation
Index
(
PIS)=
7.42
with
severe
erythema
and
edema
observed
at
72
hours;
80%
ai
II
870.2600
Skin
sensitization
MRID
42349201
Acc
No.
259676
Busan
74
(
80%
ai)
caused
delayed
contact
hypersensitivity
in
guinea
pigs
when
induced
and
challenged
by
a
40%
w/
v
aqueous
concentration
of
active
ingredient.
Sensitizer.
­­

Notes:
LC
=
Lethal
Concentration;
LD
=
Lethal
Dose;
NA
=
Not
Applicable
9
The
doses
and
toxicological
endpoints
selected
for
the
dietary
exposure
scenarios
are
summarized
in
Table
2
below:

Table
2.
Dietary
Toxicological
Endpoints
for
TCMTB
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF*
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
(
all
populations,
including
infants
and
children)
NOAEL=
25.1
mg/
kg/
day
83.55%
ai
purity
UF
=
100
(
10x
inter­
species
extrapolation
and
intra­
species
variation)

FQPA
SF
=
1x
Acute
PAD
=
0.25
mg
TCMTB/
kg/
day
Developmental
toxicity
study
in
rats
(
MRID
00154295,
92179009
(
1985))

Maternal
LOAEL
=
76.5
mg
TCMTB/
kg/
day,
based
on
clinical
signs
of
toxicity
(
ventral
alopecia,
rough
coat,
dyspnea/
wheezing,
oral
discharge,
diarrhea/
loose
stool,
urine
staining,
piloerection,
and
hunched
gait).

Acute
Dietary
(
females
13­
49)
An
endpoint
specific
for
females
13­
49
was
not
identified
because
the
Acute
Dietary
endpoint
for
all
populations
is
protective
of
developmental
effects.

Chronic
Dietary
(
all
populations)
LOAEL
=
3.8
mg/
kg/
day
81.6%
ai
purity
UF
=
300
(
10x
inter­
species
extrapolation
and
intra­
species
variation,
3x
for
use
of
a
LOAEL)

FQPA
SF
=
1x
Chronic
PAD
=
0.01
mg
ai/
kg/
day
Chronic
toxicity
study
in
dogs
(
MRID
41342201,
92179008
(
1989))

LOAEL
=
3.8
mg/
kg/
day
(
males),
based
on
decreased
body
weight
gain,
decreased
white
cells,
monocytes,
and
plasma
ALT;
decreased
uterine
weight
in
females.

Carcinogenicity
The
Agency
concluded
that
TCMTB
should
be
classified
as
Group
C
­
possible
human
carcinogen
­
and
recommended
that
for
the
purpose
of
risk
characterization,
the
Reference
Dose
(
RfD)
approach
should
be
used
for
quantitation
of
human
risk.
This
was
based
on
statistically
significant
increases
in
tumors
in
both
sexes
of
the
Sprague­
Dawley
rat:
testicular
interstitial
cell
adenomas
in
males
and
thyroid
C­
cell
adenomas
in
females.
Notes:
UF
=
uncertainty
factor,
FQPA
SF
=
FQPA
safety
factor,
NOAEL
=
no
observed
adverse
effect
level,
LOAEL
=
lowest
observed
adverse
effect
level,
PAD
=
population
adjusted
dose
(
a
=
acute,
c
=
chronic)
RfD
=
reference
dose
(
a)
Note:
an
additional
UF
of
10X
is
used
for
route
extrapolation
from
an
oral
endpoint
to
determine
if
a
confirmatory
inhalation
study
is
warranted.
If
results
are
below
a
MOE
of
1,000,
a
confirmatory
inhalation
study
may
be
required.

Developmental
toxicity
studies
were
available
in
both
the
rat
and
rabbit
for
TCMTB.
Rabbits
appear
to
be
more
sensitive
to
the
toxicity
of
TCMTB
than
rats.
In
rabbits,
the
maternal
NOAEL
and
LOAEL
were
significantly
lower
than
those
for
rats.
However,
no
developmental
effects
were
noted
in
the
rabbit
at
the
highest
dose
tested
(
32
mg
ai/
kg/
day).
In
the
rat,
adverse
developmental
effects
including
increased
fetal
and
litter
incidence
of
fused/
wavy
ribs,
10
rudimentary
cervical,
thoracic
and
lumbar
ribs
and
increased
incidence
of
sternebrae
and
pelvic
girdle
anomalies
were
noted
at
doses
of
105
mg
ai/
kg/
day,
which
was
maternally
toxic.

In
a
two­
generation
rat
reproduction
study,
there
were
no
treatment
related
effects
noted
at
the
highest
dose
tested
for
parental
toxicity
or
on
reproductive
parameters
examined
in
this
study.

General
Toxicity
Observations
Following
subchronic
oral
exposures
to
rodents,
TCMTB
caused
increased
incidence
of
mild
to
severe
stomach
lesions
characterized
by
inflammation,
hyperplasia,
necrosis,
and
ulceration.
TCMTB
resulted
in
decreased
body
weight
gains
(
78
to
84%
of
control),
food
consumption
(
87­
95%
of
control)
and
food
efficiency.
In
a
21­
day
rat
dermal
toxicity
study,
TCMTB
produced
dose­
dependant
dermal
irritation
in
all
dose
groups
beginning
on
treatment
days
3­
4,
which
progressed
to
eschar
formation.
Rats
in
the
mid
and
high
dose
group
had
ulcers,
hemorrhages
and
chronic
dermatitis.
Decreased
body
weight
gain,
food
consumption,
and
hematological
(
changes
in
hemoglobin,
hematocrit,
and
segmented
neutrophils)
and
clinical
chemistry
changes
(
blood
urea
nitrogen,
glucose,
globulins,
and
elevated
serum
aspartate
aminotransferase
(
AST)
were
also
noted.
However,
the
clinical
chemistry
changes
did
not
correspond
to
any
treatment­
related
findings
in
the
liver
or
kidney.

The
available
toxicity
data
do
no
indicate
neurotoxicity
in
the
experimental
animals
exposed
to
TCMTB
by
either
oral
or
derma
routes.

Dogs
appear
to
be
the
most
sensitive
species
to
TCMTB
toxicity
following
chronic
exposure.
In
the
chronic
dog
toxicity
study,
adverse
effects
were
noted
at
the
lowest
dose
tested
of
3.8
mg/
kg/
day.
Adverse
effects
included
decreased
body
weight
gain,
hematological
effects
(
changes
in
white
blood
cells,
monocytes),
alterations
in
clinical
chemistry
parameters
(
plasma
ALT)
and
decreased
uterine
weight
in
females.

In
the
chronic
rat
toxicity/
carcinogenicity
study,
no
adverse
effects
were
noted
at
the
highest
dose
tested
of
20
mg/
kg/
day.
However,
there
was
a
statistically
significant
increase
in
the
incidence
of
testicular
interstitial
cell
adenomas
in
males
of
mid­
and
high­
dose
levels
that
had
a
highly
significant
positive
dose­
related
trend.
Treatment
was
also
associated
with
a
possible
increased
incidence
of
thyroid
C­
cell
adenomas
in
females
of
the
mid­
and
high­
dose
levels,
which
had
a
highly
significant
positive
dose­
related
trend,
but
did
not
attain
a
statistically
significant
level
in
the
pairwise
comparison
with
concurrent
controls.

In
the
chronic
mouse
toxicity/
carcinogenicity
study,
decreased
body
weight
gain
was
noted
in
both
sexes,
while
there
was
a
statistically
increased
incidence
of
focal
and
diffuse
hyperplasia
of
duodenal
mucosa
in
males.
There
was
no
evidence
of
carcinogenicity.

Dietary
The
acute
RfD
of
TCMTB
is
0.25
mg/
kg/
day.
The
acute
RfD
was
determined
by
using
a
no­
observed
effect
level
(
NOAEL)
of
25.1
mg/
kg/
day
for
all
populations
based
on
clinical
signs
11
of
toxicity
in
maternal
rats
in
a
rat
developmental
study
(
ventral
alopecia,
rough
coat,
dyspnea/
wheezing,
oral
discharge,
diarrhea/
loose
stool,
urine
staining,
piloerection,
and
hunched
gait).
An
uncertainty
factor
of
100
(
10X
for
inter­
species
extrapolation,
10X
for
intra­
species
variability)
was
applied
to
the
NOAEL.

The
chronic
RfD
is
0.013
mg/
kg/
day
for
all
populations.
The
chronic
RfD
was
established
by
using
a
LOAEL
of
3.8
mg/
kg/
day,
which
is
based
on
a
chronic
dog
study
that
observed
decreased
body
weight
gain,
decreased
white
cells,
monocytes
and
plasma
ALT
and
decreased
uterine
weight
in
females.
An
uncertainty
factor
of
300
was
applied
(
10X
for
interspecies
extrapolation
and
intra­
species
variation,
and
3X
for
subchronic
to
chronic
extrapolation).

Incidental
Oral
The
NOAEL
for
the
short­
and
intermediate­
term
incidental
oral
endpoint
is
16
mg/
kg/
day,
based
on
a
rabbit
developmental
study.
The
target
margin
of
exposure
(
MOE)
is
100
(
10X
for
inter­
species
extrapolation
and
intra­
species
variation).

Short­,
Intermediate­
and
Long­
term
Dermal
The
short­,
intermediate­
and
long­
term
dermal
NOAEL
is
25
mg/
kg/
day,
which
is
based
on
a
dermal
toxicity
study.
The
uncertainty
factor,
or
"
target"
MOE,
for
TCMTB
dermal
exposure
is
100
for
short­
and
intermediate­
term
durations
and
300
for
long­
term
durations
(
10X
for
inter­
species
extrapolation
and
intra­
species
variation,
and
3X
for
subchronic
to
chronic
extrapolation).

Short­
and
Intermediate­
term
Inhalation
The
short­
and
intermediate­
term
inhalation
endpoint
is
based
on
an
oral
rabbit
developmental
toxicity
study
NOAEL
of
16
mg/
kg/
day.
The
long­
term
inhalation
endpoint
is
LOAEL
of
3.8
mg/
kg/
day,
based
on
a
chronic
toxicity
study
in
dogs.
In
the
absence
of
routespecific
data,
it
was
conservatively
assumed
that
inhalation
absorption
is
equivalent
to
oral
absorption
(
100%).
The
target
MOE
for
TCMTB
is
100
for
short­
and
intermediate­
term
durations
and
300
for
long­
term
durations
(
10X
for
inter­
species
extrapolation
and
intra­
species
variation,
3X
for
subchronic
to
chronic
extrapolation).

Carcinogenicity
Classification
TCMTB
has
been
classified
as
group
C,
possible
human
carcinogen.
In
the
chronic
toxicity/
carcinogenicity
study
in
rats
there
was
a
statistically
significant
increase
in
the
incidence
of
testicular
interstitial
cell
adenomas
in
males
of
mid
(
8
mg/
kg/
day)
and
high­
dose
(
20
mg/
kg/
day)
levels,
that
had
a
highly
significant
positive
dose­
related
trend.
Treatment
was
also
associated
with
a
possible
increased
incidence
of
thyroid
C­
cell
adenomas
in
females
of
the
midand
high­
dose
levels,
which
had
a
highly
significant
positive
dose­
related
trend,
but
did
not
attain
a
statistically
significant
level
in
the
pairwise
comparison
with
concurrent
controls.
No
historical
data
were
available
for
review.
12
The
Agency
recommended
that
for
the
purpose
of
risk
characterization
the
Reference
Dose
(
RfD)
approach
be
used
for
quantifying
the
TCMTB
cancer
risk.
The
RfD
approach
is
considered
to
be
protective
of
any
carcinogenic
effect
(
the
chronic
dietary
endpoint
is
.01
mg/
kg/
day
compared
to
.08
mg/
kg/
day).
Further,
the
RfD
approach
was
recommended
because
there
is
no
apparent
compound­
related
increase
in
tumors
in
the
mouse
carcinogenicity
study
and
there
is
no
apparent
concern
for
mutagenicity.

Mutagenicity
Potential
TCMTB
was
found
to
be
negative
for
mutagenicity
in
the
gene
mutation
assay
with
bacteria
and
did
not
cause
an
increase
in
unscheduled
DNA
synthesis
(
UDS)
in
the
rat
hepatocytes
assay.
TCMTB
was
also
found
to
be
negative
for
chromosomal
aberrations
in
the
in
vivo
micronucleus
assay
in
mice.
Therefore,
TCMTB
is
not
mutagenic
or
genotoxic.

Endocrine
Disruption
Potential
EPA
is
required
under
the
Federal
Food
Drug
and
Cosmetic
Act
(
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
such
endocrine
effects
as
the
Administrator
may
designate."
Following
recommendations
of
its
Endocrine
Disruptor
and
Testing
Advisory
Committee
(
EDSTAC),
EPA
determined
that
there
was
a
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
the
Program
include
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).
When
the
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
Endocrine
Disrupting
Screening
Program
(
EDSP)
have
been
developed,
TCMTB
may
be
subjected
to
additional
screening
and/
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

2.
Metabolite
Assessment
TCMTB
has
several
metabolites,
including
2­
mercaptobenzothiazole
(
2­
MBT)
and
2­
benzothiazolesulfonic
acid
(
2­
BTSA).
The
Agency's
Risk
Assessment
Review
Committee
(
RARC)
met
and
determined
that
the
residue
of
concern
for
tolerance
expression
and
risk
assessment
is
TCMTB
in/
on
plants.
2­
MBT
and
other
TCMTB
metabolites
were
not
found
at
significant
levels
to
be
considered
residues
of
concern.
The
determination
of
the
residues
of
concern
in
plant
commodities
was
based
on
tomato
and
melon
metabolism
studies
and
available
toxicity
data.
2­
BTSA
was
found
at
significant
levels
(
62%
in
tomato
fruit);
however,
it
was
determined
that
it
should
be
excluded
as
a
residue
of
concern
because
it
is
expected
to
be
less
toxic
than
the
parent
TCMTB.
2­
BTSA
does
not
contribute
significantly
to
the
chronic
toxicity
of
the
parent.
This
decision
is
considered
preliminary
pending
the
results
of
confirmatory
metabolism
data
that
are
required
to
support
the
currently
registered
uses
of
TCMTB.
13
For
drinking
water,
the
residues
of
concern
included
TCMTB
and
2­
MBT,
based
on
an
available
aerobic
soil
metabolism
study
(
MRID
43532201).
Although
2­
MBT
is
distinctly
less
toxic
than
the
parent,
it
was
conservatively
included
in
the
drinking
water
assessment
because
it
is
a
toxic
metabolite
of
concern.
All
other
metabolites
were
not
found
at
significant
levels;
and
are
not
to
be
considered
residues
of
concern.

A
summary
of
the
decisions
concerning
the
residues
of
concern
in
plants
and
drinking
water
are
presented
below
in
Table
3.
For
further
information
regarding
the
metabolism
assessment
of
TCMTB
please
refer
to,
3.0
Metabolism
Assessment
in
the
"
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
August
1,
2006.

Table
3.
Summary
of
TCMTB
Residues
to
be
Included
in
the
Risk
Assessment
and
Tolerance
Expression
Matrix
Residues
Included
in
Risk
Assessment
Residues
Included
in
Tolerance
Expression
Primary
crop
­
barley,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat
TCMTB
TCMTB
Plants
Rotational
crop
NA
=
not
applicable
NA
Ruminant
NA
NA
Livestock
Poultry
NA
NA
Drinking
water
TCMTB
and
2­
MBT
NA
NA=
Not
applicable
3.
FQPA
Safety
Factor
The
FQPA
Safety
Factor
(
as
required
by
the
Food
Quality
Protection
Act
of
1996)
is
intended
to
provide
an
additional
10­
fold
safety
factor
(
10X),
to
protect
for
special
sensitivity
in
infants
and
children
to
specific
pesticide
residues
in
food,
drinking
water,
or
residential
exposures,
or
to
compensate
for
an
incomplete
database.
The
Agency
has
concluded
that
the
FQPA
Safety
Factor
should
be
removed
(
i.
e.,
reduced
to
1X)
for
TCMTB
based
on:
(
1)
a
complete
toxicology
data
base
with
respect
to
assessing
the
increased
susceptibility
to
infants
and
children
as
required
by
FQPA;
(
2)
a
lack
of
evidence
that
TCMTB
will
induce
neurotoxic
effects;
(
3)
no
evidence
of
increased
susceptibility
to
the
fetus
following
in
utero
exposure
in
the
prenatal
developmental
toxicity
studies;
(
4)
no
evidence
of
increased
susceptibility
to
the
offspring
when
adults
are
exposed
in
the
two­
generation
reproductive
study;
and
(
5)
the
risk
assessment
does
not
underestimate
the
potential
exposure
for
infants
and
children.
Based
on
the
analysis
of
submitted
developmental
toxicity
studies,
the
Agency
determined
that
no
special
FQPA
Safety
Factor
was
needed
since
there
were
no
residual
uncertainties
for
pre­
and/
or
postnatal
toxicity.
14
4.
Population
Adjusted
Dose
(
PAD)

Dietary
risk
is
characterized
in
terms
of
the
Population
Adjusted
Dose
(
PAD),
which
reflects
the
reference
dose
(
RfD),
either
acute
or
chronic,
that
has
been
adjusted
to
account
for
the
FQPA
Safety
Factor
(
SF).
This
calculation
is
performed
for
each
population
subgroup.
A
risk
estimate
that
is
less
than
100%
of
the
acute
or
chronic
PAD
is
not
of
concern.
The
Agency
has
conducted
a
dietary
exposure
and
risk
assessment
for
the
use
of
TCMTB
as
a
fungicide
for
seed
treatment
as
well
as
a
slimicide
and
materials
preservative
in
pulp
and
paper
manufacturing.

a.
Acute
PAD
Acute
dietary
risk
for
TCMTB
is
assessed
by
comparing
acute
dietary
exposure
estimates
(
in
mg/
kg/
day)
to
the
acute
Population
Adjusted
Dose
(
aPAD).
Acute
dietary
risk
is
expressed
as
a
percent
of
the
aPAD.
The
aPAD
is
the
acute
reference
dose
(
0.25
mg/
kg/
day)
modified
by
the
FQPA
safety
factor.
The
TCMTB
acute
reference
dose
was
derived
from
a
developmental
toxicity
study
in
rats
in
which
a
NOAEL
(
25
mg/
kg/
day)
was
determined.
Acute
dietary
exposure
was
estimated
for
all
populations,
including
infants
and
children.
The
TCMTB
aPAD
is
0.25
mg/
kg/
day
based
on
a
reference
dose
of
0.25
mg/
kg/
day
and
an
FQPA
safety
factor
of
1X.

b.
Chronic
PAD
Chronic
dietary
risk
for
TCMTB
is
assessed
by
comparing
chronic
dietary
exposure
estimates
(
in
mg/
kg/
day)
to
the
chronic
Population
Adjusted
Dose
(
cPAD).
Chronic
dietary
risk
is
expressed
as
a
percent
of
the
cPAD.
The
cPAD
is
the
chronic
reference
dose
(
0.01
mg/
kg/
day)
modified
by
the
FQPA
safety
factor.
The
cPAD
was
derived
from
a
chronic
toxicity
study
in
dogs
in
which
the
LOAEL
(
3.8
mg/
kg/
day)
was
determined.
The
TCMTB
cPAD
is
0.01
mg/
kg/
day
based
on
a
reference
dose
of
0.01
mg/
kg/
day,
which
incorporates
the
FQPA
safety
factor
(
1X)
for
the
overall
U.
S.
population
and
all
population
subgroups.

5.
Dietary
Exposure
Assumptions
Acute
and
chronic
dietary
exposure
assessments
were
conducted
for
the
use
of
TCMTB
as
a
fungicide
for
seed
treatment
as
well
as
an
antimicrobial
pesticide
for
pulp
and
paper
products.

Seed
Treatment
Use
For
the
seed
treatment
use
of
TCMTB,
conservative
acute
and
chronic
dietary
exposure
assessments
incorporated
maximum
theoretical
concentration
factors
for
all
commodities,
existing
tolerance
level
residues,
and
100%
crop
treatment.
These
exposure
assessments
were
conducted
using
the
Dietary
Exposure
Evaluation
Model
software
with
the
Food
Commodity
Intake
Database
(
DEEM­
FCID
 
,
Version
2.03),
which
uses
food
consumption
data
from
the
USDA's
Continuing
Surveys
of
Food
Intakes
by
Individuals
(
CSFII)
from
1994­
1996
and
1998.
15
Antimicrobial
Use
The
dietary
risk
assessment
conducted
for
the
antimicrobial
use
of
TCMTB
considered
only
potential
food
exposures
from
the
antimicrobial
uses
of
TCMTB
because
this
use
is
expected
to
have
minimal
impact
on
drinking
water
exposure.
In
the
absence
of
residue
data,
the
Agency
estimated
antimicrobial
residue
levels
that
may
occur
in
food
that
contacts
treated
pulp
and
paper
products
from
the
maximum
application
rates
on
TCMTB
product
labels.
When
assessing
the
antimicrobial
dietary
risks
of
TCMTB
the
Agency
used
FDA's
Center
for
Food
Safety
&
Applied
Nutrition's
(
CFSAN)
screening­
level
approach
as
presented
in
the
"
Preparation
of
Food
Contact
Notifications
and
Food
Additive
Petitions
for
Food
Contact
Substances:
Chemistry
Recommendations"
dated
April
2002.
Using
the
maximum
application
rates
and
US
FDA's
default
assumptions,
"
worst­
case"
dietary
concentration
values
were
calculated
by
the
Agency.
This
model
was
used
to
determine
the
estimated
daily
intake
(
EDI).

In
addition,
the
Agency
estimated
a
total
cumulative
dietary
intake
of
TCMTB
that
could
result
from
simultaneous
exposure
from
the
three
antimicrobial
uses
that
were
assessed
(
pulp/
paper
slimicide
use;
paper
coating
use;
and
paper
adhesive
preservative
use).

6.
Dietary
Risk
Assessment
The
Agency
conducted
a
dietary
exposure/
risk
assessment
for
the
use
of
TCMTB
as
a
fungicide
for
seed
treatment
as
well
as
an
antimicrobial
pesticide
in
pulp
and
paper
products.
Generally,
a
dietary
risk
estimate
that
is
less
than
100%
of
the
acute
or
chronic
PAD
(
aPAD
or
cPAD)
does
not
exceed
the
Agency's
risk
concerns.
A
summary
of
acute
and
chronic
risk
estimates
are
shown
in
Tables
4
and
5.

a.
Dietary
Risk
from
Food
and
Drinking
Water
Seed
Treatment
Use
The
Agency
has
determined
that
the
acute
dietary
risk
estimates
do
not
exceed
the
Agency's
level
of
concern
(
less
then
100%
of
the
aPAD)
at
the
95th
exposure
percentile
for
the
United
States
population
(
less
than
1%
of
the
aPAD)
and
all
population
subgroups.
The
highest
exposed
population
subgroup
was
children
3­
5
years
old
at
2%
of
the
aPAD.

The
chronic
dietary
risk
assessment
concluded
that
for
all
supported
agricultural
uses
of
TCMTB,
the
chronic
risk
estimates
are
below
the
Agency's
level
of
concern
(
less
than
100%
of
the
cPAD)
for
the
general
U.
S.
population
(
7%
of
the
cPAD)
and
all
population
subgroups.
The
highest
exposed
population
subgroup
was
children
3­
5
years
old
at
17%
of
the
cPAD.
16
Table
4.
Seed
Treatment
Use
Summary
of
Dietary
Exposure
and
Risk
for
TCMTB
Using
DEEM­
FCID
(
Food
and
Water)

Acute
Dietary
(
95th
Percentile)
Chronic
Dietary
Population
Subgroup
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
b
Dietary
Exposure
(
mg/
kg/
day)
%
cPAD
b
General
U.
S.
Population
0.002430
<
1
0.000888
7
All
Infants
(<
1
year
old)
0.003256
1
0.000994
8
Children
1­
2
years
old
0.004467
2
0.002054
16
Children
3­
5
years
old
a
0.004581
2
0.002226
17
Children
6­
12
years
old
0.003370
1
0.001625
13
Youth
13­
19
years
old
0.002109
<
1
0.000936
7
Adults
20­
49
years
old
0.001547
<
1
0.000680
5
Adults
50+
years
old
0.001192
<
1
0.000542
4
Females
13­
49
years
old
0.001529
<
1
0.000671
5
a
The
bolded
values
represent
the
highest
exposed
populations
for
each
percentile.
b
%
PAD
=
dietary
exposure
(
mg/
kg/
day)
/
aPAD
or
cPAD,
where
aPAD=
0.25
mg/
kg/
day
(
for
all
populations)
and
cPAD=
0.013
mg/
kg/
day
(
for
all
populations)

Antimicrobial
Use
TCMTB
is
used
as
a
slimicide
and
paper
coating
preservative
for
controlling
bacteria,
fungi
and
yeasts
that
cause
deterioration
of
paper
and
paperboard
products
and
used
to
preserve
paper­
adhesive
formulations.

The
results
of
the
acute
dietary
risk
estimates
for
the
antimicrobial
use
of
TCMTB
are
below
the
Agency's
level
of
concern
for
all
population
subgroups
(<
1%
of
the
aPAD
for
all
use
sites).
The
highest
dietary
risk
estimate
was
at
0.66%
of
the
aPAD
for
infants
and
children.
The
chronic
dietary
analysis
indicates
that
all
risk
estimates
are
below
the
Agency's
level
of
concern
for
all
population
subgroups
(<
13%
of
cPAD
for
all
use
sites).
The
highest
dietary
risk
estimate
was
at
12.8%
of
the
cPAD,
for
combined
exposure
to
infants
and
children.
17
Table
5.
Antimicrobial
Use
Summary
of
Dietary
Exposure
and
Risk
for
TCMTB
Acute
Dietary
Chronic
Dietary
Population
Subgroup
Dietary
Exposure
(
mg/
kg/
day)
a
%
aPAD
b
Dietary
Exposure
(
mg/
kg/
day)
a
%
cPAD
b
Pulp/
Paper
Slimicide
Adult
Male
0.00024
0.096
0.00024
1.8
Adult
Female
(
13­
50
years
old)
0.00028
0.11
0.00028
2.2
Infants/
Children
0.00056
0.22
0.00056
4.3
Paper
Coating
Preservative
Adult
Male
0.00017
0.07
0.00017
1.31
Adult
Female
(
13­
50
years
old)
0.0002
0.08
0.0002
1.54
Infants/
Children
0.0004
0.16
0.0004
3.08
Paper
Adhesive
Preservative
Adult
Male
0.00030
0.12
0.00030
2.3
Adult
Female
(
13­
50
years
old)
0.00035
0.14
0.00035
2.7
Infants/
Children
0.0007
0.28
0.0007
5.38
Cumulative
Adult
Male
0.00071
0.29
0.00071
5.41
Adult
Female
(
13­
50
years
old)
0.00083
0.33
0.00083
6.44
Infants/
Children
0.0017
0.66
0.0017
12.8
a
Acute
and
chronic
exposure
analysis
based
on
body
weights
of
70kg,
60
kg,
and
15
kg
for
adult
males,
females
and
children,
respectively.
b
%
PAD
=
dietary
exposure
(
mg/
kg/
day)
/
aPAD
or
cPAD,
where
aPAD=
0.25
mg/
kg/
day
(
for
all
populations)
and
cPAD=
0.013
mg/
kg/
day
(
for
all
populations)

b.
Dietary
Risk
from
Drinking
Water
The
Agency
estimated
drinking
water
exposures
for
the
seed
treatment
use
of
TCMTB,
only.
There
are
no
antimicrobial
uses
associated
with
TCMTB
that
are
expected
to
impact
either
surface
or
groundwater
resources.

The
seed
treatment
drinking
water
estimates
were
incorporated
directly
into
the
dietary
risk
assessment.
Thus,
the
drinking
water
and
food
assessments
are
combined
into
the
acute
and
chronic
dietary
risk
estimates
where
risk
is
shown
as
%
PAD.
The
drinking
water
analysis
was
18
based
on
a
derivation
of
estimated
upper
bound
Tier
I
drinking
water
concentrations
from
TCMTB
seed
treatment
uses,
which
were
based
on
the
FQPA
Index
Reservoir
Screening
Tool
(
FIRST).
Both
TCMTB
and
its'
degradate,
2­
MBT,
were
included
in
the
drinking
water
estimates.
2­
MBT
is
distinctly
less
toxic
than
the
parent;
but
was
conservatively
included
in
the
drinking
water
assessment
because
it
is
considered
a
toxic
metabolite
of
concern.

A
number
of
conservative
assumptions
related
to
runoff
and
leaching
were
utilized
as
inputs
including:
a
maximum
application
rate
of
0.041
lb
ai/
acre,
no
potential
degradation
and
transformation
reactions
occur,
no
partitioning
between
the
liquid
phase
and
the
solid
phase
occurs,
and
that
TCMTB
does
not
sorb
to
the
seed
coat
(
only
to
the
soil).

For
surface
drinking
water,
results
from
FIRST
indicate
that
the
peak
(
acute)
concentration
of
TCMTB
and
its'
degradates
is
not
likely
to
exceed
0.94
ug/
L
(
ppb)
and
that
the
average
annual
(
chronic)
concentration
is
not
likely
to
exceed
0.67
ug/
L
(
ppb).
These
drinking
water
concentrations
were
used
in
the
acute
and
chronic
dietary
risk
assessment
for
the
agricultural
uses
of
TCMTB
as
was
discussed
above.

For
further
details
regarding
the
dietary
risk
assessment
conducted
for
the
seed
treatment
use
of
TCMTB,
refer
to
the
"
Drinking
Water
Assessment
for
the
Use
of
the
Fungicide
of
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
as
a
Seed
Treatment
on
Cotton,
Wheat,
Barley,
Oats,
Rice,
Sugar
Beets,
and
Safflower,"
dated
January
31,
2006.

It
should
be
noted
that
the
Agency
estimated
higher
concentrations
for
exposure
to
aquatic
animals
resulting
from
the
antisapstain
use
than
were
used
in
the
drinking
water
assessment.
These
levels
were
not
considered
appropriate
for
use
in
the
drinking
water
assessment
due
to
the
very
conservative
nature
of
the
model
used,
that
the
model
estimates
runoff
concentrations
and
not
water
body
concentrations,
and
the
fact
that
the
model
does
not
account
for
dilution.

7.
Residential
Risk
Assessment
Residential
exposure
from
TCMTB
can
occur
from
the
antimicrobial
uses
of
TCMTB.
The
residential
exposure
assessment
considers
all
potential
pesticide
exposure,
other
than
exposure
due
to
residues
in
food
and
drinking
water.
Exposure
may
occur
during
and
after
application
methods
including
painting
via
brush/
roller
and
airless
sprayer.
Each
route
of
exposure
(
oral,
dermal,
inhalation)
is
assessed,
where
appropriate,
and
risk
is
expressed
as
a
Margin
of
Exposure
(
MOE),
which
is
the
ratio
of
estimated
exposure
to
an
appropriate
No
Observed
Effect
Level
(
NOAEL)
dose.
Based
on
the
application
methods,
TCMTB
has
been
assessed
for
the
residential
mixing/
loading/
applicator
(
or
"
handler")
exposure.

a.
Residential
Toxicity
The
toxicological
endpoints
and
associated
uncertainty
factors
used
for
assessing
the
nondietary
residential
and
occupational
risks
for
TCMTB
are
listed
in
Table
6.
19
A
MOE
greater
than
or
equal
to
100
is
considered
adequately
protective
for
the
residential
exposure
assessment
for
the
dermal
and
inhalation
routes
of
exposure.
The
MOE
of
100
includes
10x
for
inter­
species
extrapolation,
10x
for
intra­
species
variation.

Table
6.
Residential
and
Occupational
Toxicological
Doses
and
Endpoints
for
TCMTB
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Target
MOEs/
UFs
FQPA
Safety
Factor
for
Risk
Assessment
Study
and
Toxicological
Effects
Short­
Term
and
Intermediate­
Term
Incidental
Oral
(
1­
30
days;
30
days­
6months)
NOAEL=
16.2
mg
ai/
kg/
day
81%
ai
purity
(
20
mg
TCMTB/
kg/
day)
MOE
=
100
(
ST
and
IT)

(
10X
for
interspecies
extrapolation
and
intra­
species
variation)
Developmental
toxicity
study
in
rabbits
(
MRID
40075101,
40075102,
92179011,
(
1986))

LOAEL
=
32
mg
ai/
kg/
day
(
40
mg
TCMTB/
kg/
day)
based
on
decreased
body
weight
gain
and
food
consumption
in
maternal
animals.

Short­
Term,
Intermediate­
Term
and
Long­
Term
Dermal
Exposure
NOAEL=
25
mg/
kg/
day
82.33%
ai
purity
(
20.6
mg
ai/
kg/
day)
MOE
=
100
(
ST
and
IT)

MOE
=
300
(
LT)
(
10X
for
interspecies
extrapolation
and
intra­
species
variation,
and
3X
for
duration
of
exposure)
21­
Day
dermal
toxicity
study
in
rats
(
MRID
41655801)

LOAEL
=
100
mg
TCMTB/
kg/
day
(
82.3
mg
ai/
kg/
day)
based
on
decreased
body
weight
gain,
food
consumption
and
hematological
and
clinical
chemistry
changes
Short­
Term
and
Intermediate­
Term
Inhalation
Exposure
NOAEL
=
16.2
mg
ai/
kg/
day
81%
ai
purity
(
20
mg
TCMTB/
kg/
day)

Absorption
=
100%
(
inhalation
and
oral
equivalent)
MOE
=
100
(
ST
and
IT)

(
10X
for
interspecies
extrapolation
and
intra­
species
variation)
Developmental
toxicity
study
in
rabbits
(
MRID
40075102)

LOAEL
=
32
mg
ai/
kg/
day
(
40
mg
TCMTB/
kg/
day)
based
on
decreased
body
weight
gain
and
food
consumption
in
maternal
animals.

Long­
Term
Inhalation
Exposure
LOAEL
=
3.8
mg/
kg/
day
81.6%
ai
purity
Absorption
=
100%
(
inhalation
and
oral
equivalent)
MOE
=
300
(
a)
(
LT)

(
10X
for
interspecies
extrapolation
and
intra­
species
variation
and
3X
for
use
of
a
LOAEL)
Chronic
toxicity
study
in
dogs
(
MRID
41342201,
92179008
(
1989))

LOAEL
=
3.8
mg/
kg/
day
(
males)
based
on
decreased
body
weight
gain,
decreased
white
cells,
monocytes,
and
plasma
ALT.
Decreased
uterine
weight
in
females.
20
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Target
MOEs/
UFs
FQPA
Safety
Factor
for
Risk
Assessment
Study
and
Toxicological
Effects
Short­
and
Intermediate­
Term
Incidental
Oral
(
1­
30
days;
30
days­
6
months)
NOAEL=
16.2
mg
ai/
kg/
day
81%
ai
purity
(
20
mg
TCMTB/
kg/
day)
MOE
=
100
(
10X
for
interspecies
extrapolation
and
intra­
species
variation)
Developmental
toxicity
study
in
rabbits
(
MRID
40075101,
40075102,
92179011
(
1986))

LOAEL
=
32
mg
ai/
kg/
day
(
40
mg
TCMTB/
kg/
day),
based
on
decreased
body
weight
gain
and
food
consumption
in
maternal
animals.

Cancer
The
Agency
concluded
that
TCMTB
should
be
classified
as
a
"
Group
C­
Possible
Human
Carcinogen"
and
recommended
that
for
the
purpose
of
risk
characterization,
the
Reference
Dose
(
RfD)
approach
should
be
used
for
quantitation
of
human
risk.
The
chronic
RfD
is
protective
of
any
potential
carcinogenic
effect.
This
decision
was
based
on
statistically
significant
increases
in
tumors
in
both
sexes
of
the
Sprauge­
Dawley
rat
(
testicular
interstitial
cell
adenomas
in
males
and
thyroid
C­
cell
adenomas
in
females).

Notes:
UF
=
uncertainty
factor,
NOAEL
=
no
observed
adverse
effect
level,
LOAEL
=
lowest
observed
adverse
effect
level,
LOC
=
level
of
concern,
MOE
=
margin
of
exposure
(
a)
Note:
An
additional
uncertainty
factor
(
UF)
of
10X
is
used
for
route
extrapolation
from
an
oral
endpoint
to
determine
if
a
confirmatory
inhalation
study
is
warranted.
If
results
are
below
a
MOE
of
1,000
a
confirmatory
inhalation
study
may
be
required.

b.
Residential
Handlers
i.
Exposure
Assessment
Residential
exposure
can
occur
through
the
application
of
TCMTB
preserved
paint
via
airless
sprayer
or
paintbrush.
EPA
selected
high­
end
scenarios
for
each
use
site
for
the
residential
handler
exposure
assessment.
These
scenarios
are
listed
below:

°
Painting
with
an
airless
sprayer
°
Painting
with
a
brush/
roller
There
was
no
chemical­
specific
exposure
data
to
assess
paint
application
with
a
brush
roller
or
airless
sprayer.
Therefore,
dermal
and
inhalation
exposures
were
assessed
for
these
scenarios
using
the
Pesticide
Handler
Exposure
Database
(
PHED,
Version
1.1)
and
values
were
found
in
the
Residential
Exposure
SOPs
(
U.
S.
EPA,
1997a,
2001).
The
dermal
and
inhalation
exposures
from
these
techniques
have
been
normalized
by
the
amount
of
active
ingredient
handled
and
reported
as
unit
exposures
(
UE),
which
are
expressed
as
mg/
lb
of
active
ingredient
handled.

Maximum
application
rates,
related
use
information
and
Agency
standard
values
were
used
to
assess
residential
handler
exposure.
For
example,
it
was
conservatively
assumed
that
a
resident
applies
15
gallons
of
paint
per
day
using
an
airless
sprayer
and
2
gallons
of
paint
per
day
using
a
brush/
roller.
The
residential
handler
scenarios
were
assumed
to
be
of
short­
term
duration
(
1­
30
days).
21
ii.
Risk
Assessment
Based
on
toxicological
criteria
and
potential
for
exposure,
the
Agency
has
conducted
dermal
and
inhalation
exposure
assessments.
A
MOE
greater
than
or
equal
to
100
is
considered
adequately
protective
for
the
residential
exposure
assessment
for
the
dermal
and
inhalation
routes
of
exposure.
The
MOE
of
100
includes
10x
for
inter­
species
extrapolation,
10x
for
intraspecies
variation.

All
of
the
inhalation
MOEs
for
residential
handlers
are
above
the
target
MOE
of
100
and,
therefore,
are
not
of
concern.
For
the
residential
handler
dermal
risk
assessment,
dermal
MOEs
are
below
the
target
of
100
and,
therefore,
are
of
concern
(
MOE
of
10
for
airless
sprayer,
MOE
of
25
for
paint
brush).
In
addition,
total
dermal
and
inhalation
risk
estimates
were
of
concern
primarily
because
of
the
dermal
route
of
exposure.
A
summary
of
the
residential
handler
exposures
and
risks
are
presented
on
Table
7.

Table
7.
Residential
Handler
Risk
Summary
(
Short­
Term
Duration)
Exposure
Scenario
Use
site
Dermal
Dose
(
mg/
kg/
day)
a
Inhalation
Dose
(
mg/
kg/
day)
b
Dermal
MOEc
Inhalation
MOEd
Total
Dermal
and
Inhalation
MOE
Airless
Sprayer
Residential/
Household
Premises
2.54
0.0267
10
600
9.8
Paintbrush/
Roller
Residential/
Household
Premises
0.986
0.00122
25
13,000
25
a
Dermal
Dose
(
mg/
kg/
day)
=
[
Unit
dermal
exposure
(
mg/
lb
ai)
*
Use
rate
(
lb
ai/
lb
product
or
lb
ai/
gal
product)
*
Amount
handled
per
day
(
lb
product/
day)]
/
Body
weight
(
kg)
b
Inhalation
Dose
(
mg/
kg/
day)
=
[
Unite
inhalation
exposure
(
mg/
lb
ai)
*
Use
rate
(
lb
ai/
lb
product
or
lb
ai/
gal
product)
*
Amount
handled
per
day
(
lb
product/
day)
*
inhalation
absorption
(
1.0)]
/
Body
Weight
(
kg)

c
Dermal
MOE
=
Dermal
NOAEL
(
mg/
kg/
day)
/
Dermal
Dose
(
mg/
kg/
day),
where
the
NOAEL
is
25
mg/
kg/
day
from
the
sub­
chronic
rat
dermal
toxicity
study
d
Inhalation
MOE
=
Inhalation
NOAEL
(
mg/
kg/
day)
/
Inhalation
Dose
(
mg/
kg/
day),
where
the
inhalation
NOAEL
of
16
mg/
kg/
day
is
from
an
oral
rabbit
developmental
study.
In
absence
of
data,
inhalation
absorption
is
assumed
to
be
equivalent
to
oral
absorptions.

c.
Residential
Post­
application
i.
Exposure
Assessment
Residential
post­
application
exposures
result
when
adults
and
children
come
in
contact
with
TCMTB
in
areas
where
pesticide
end­
use
products
have
recently
been
applied
(
e.
g.,
treated
textiles/
carpeting),
or
when
children
incidentally
ingest
the
pesticide
residues
through
mouthing
the
treated
end
products/
treated
articles
(
i.
e.,
hand­
to­
mouth
or
object­
to­
mouth
contact).
The
residential
post­
application
scenarios
considered
in
this
assessment
are
from
exposure
to
residues
on
carpets
that
have
been
treated
with
TCMTB
and
wearing
clothing
that
was
treated
with
TCMTB.
22
There
is
the
potential
for
dermal
exposure
to
toddlers
crawling
on
carpets
preserved
with
TCMTB.
Short­
term
dermal
risks
to
children
have
been
identified,
as
the
preservative
is
applied
only
during
the
manufacturing
of
the
carpet.
In
addition
to
dermal
exposure,
infants
crawling
on
treated
floors
will
also
be
exposed
to
TCMTB
via
incidental
oral
exposure
through
hand­
tomouth
transfer.
To
calculate
incidental
ingestion
exposure
to
TCMTB
due
to
hand­
to­
mouth
transfer,
the
scenarios
established
in
EPA's
"
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments"
were
used.

The
Agency
evaluated
the
following
three
post­
application
scenarios,
which
are
considered
to
be
representative
of
all
possible
residential
exposure
scenarios:

°
Contact
with
treated
carpets
by
children
(
incidental
oral
and
dermal
exposure
to
children);
°
Wearing
treated
textiles/
leather
products
(
dermal
exposure
to
children
and
adults);
°
Mouthing
treated
textiles
such
as
clothing/
blankets/
leather
products
(
incidental
oral
exposure
to
children).

For
treated
textiles/
leather
products,
the
Agency
believes
exposures
are
primarily
shortterm
because
residents
are
assumed
to
be
exposed
to
treated
textiles
with
varying
active
ingredients
and
that
these
textiles
have
not
exclusively
been
treated
with
TCMTB.
However,
if
the
products
are
used
on
a
routine
basis
(
i.
e.,
once
a
week
or
impregnated
into
carpets
as
materials
preservative)
and
the
active
ingredient
has
a
long
indoor
half­
life,
exposures
may
occur
over
an
intermediate­
term
(
30
days­
6
months).
The
Agency
did
not
have
residue
dissipation
data
or
reliable
use
pattern
data,
including
the
frequency
and
duration
use
of
antimicrobial
products
in
residential
settings.
Because
of
this
lack
of
data,
intermediate­
term
exposure
was
assessed
to
provide
an
upper­
bound
estimate
of
exposure
to
treated
textiles.

A
number
of
conservative
assumptions
were
used
in
assessing
post­
application
risks
including
maximum
application
rates
from
TCMTB
product
labels.
In
addition,
quantities
handled/
treated
were
estimated
based
on
information
form
various
resources,
including
the
Draft
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000,
2001)
and
standard
Agency
residential
SOP
assumptions.
Standard
values
were
not
available
for
the
textile
and
treated
leather
product
uses.
For
these
scenarios,
it
was
assumed
that
either
100%
or
5%
of
TCMTB
could
transfer
and
be
available
for
dermal
contact.

ii.
Risk
Assessment
Based
on
toxicological
criteria
and
potential
for
exposure,
the
Agency
has
conducted
dermal
and
incidental
oral
exposure
assessments.
A
MOE
greater
than
or
equal
to
100
is
considered
adequately
protective
for
the
residential
exposure
assessment
for
the
dermal,
incidental
oral
and
inhalation
routes
of
exposure.
The
MOE
of
100
includes
10x
for
interspecies
extrapolation
and
10x
for
intra­
species
variation.

The
residential
post­
application
risk
assessment
identifies
short­
term
(
1­
30
days)
and
intermediate­
term
(
1­
6
month)
exposure
doses
based
on
the
reported
toxicology
endpoints
for
TCMTB.
Because
the
toxicological
endpoints
are
identical
for
short­
and
intermediate­
term
23
durations
for
both
dermal
and
incidental
oral
exposures,
the
Agency
calculated
a
total
MOE
for
children.

The
short­
term
and
intermediate­
term
MOEs
for
dermal
contact
with
treated
clothing/
leather
products
are
of
concern
for
both
young
children
and
adults
(
MOEs
are
less
than
1,
assuming
a
100%
transfer
factor;
MOEs
are
less
than
10,
assuming
a
5%
transfer
factor).
In
addition,
the
dermal
MOE
is
of
concern
for
young
children
crawling
on
treated
carpets
(
MOE
of
2).
TCMTB
is
a
dermal
sensitizer
and
thus,
there
is
a
potential
for
adverse
dermal
allergic
reactions
from
direct
skin
contact
of
treated
textiles.

The
short­
and
intermediate­
term
MOEs
for
incidental
oral
ingestion
of
treated
carpets
by
children
exceeds
the
Agency's
level
of
concern
(
MOE
of
4).
In
addition,
the
short­
term
oral
MOE
for
children
mouthing
treated
textiles/
leather
products
is
also
a
risk
of
concern
as
the
MOE
(
MOE
of
21)
is
below
the
target
of
100.

As
shown
in
Table
8,
the
total
MOE
for
children
who
may
contact
TCMTB
treated
carpet
and
treated
clothing/
leather
products
is
less
then
1
and,
therefore,
the
total
(
oral
and
dermal
exposures
combined)
MOE
for
children
is
of
concern.

Table
8
presents
a
summary
of
the
short­
term
and
intermediate­
term
residential
postapplication
exposures
and
risk
estimates.

Table
8.
Antimicrobial
Short­
and
Intermediate­
term
Residential
Post­
application
Exposures
and
Risk
Summary
Dose
a
(
mg/
kg/
day)
MOEb
(
Target
MOE>
100)
Scenario
Child
Adult
Child
Adult
Dermal
Exposure
Treated
carpets
15.6
mg/
kg/
day
NA
2
NA
4.3
mg/
kg/
day
(
5%
transfer)
2.7mg/
kg/
day
(
5%
transfer)
5.8
(
5%
transfer)
9.1
(
5
%
transfer)
Treated
clothing/
leather
products
86
mg/
kg/
day
(
100%
transfer)
55
mg/
kg/
day
(
100%
transfer)
<
1
(
100%
transfer)
<
1
(
100%
transfer)
Incidental
Oral
Exposure
Treated
carpets
3.81
mg/
kg/
day
NA
4.2
NA
Treated
clothing/
leather
products
0.758
mg/
kg/
day
NA
21
NA
TOTAL
MOE
RISK
ESTIMATE
NA
<
1
c
NA
NA=
Not
applicable
a
Dose
calculations
for
each
scenario
above
are
outlined
in
the
attached
Occupational/
Residential
Assessment
(
memo
from
S.
Mostaghimi,
February
2006).
b
MOE=
NOAEL
(
mg/
kg/
day)
/
PDR
(
mg/
kg/
day).
Oral
NOAEL
is
16
mg/
kg/
day;
dermal
NOAEL
is
25
mg/
kg/
day.
c
Total
MOE
includes
carpet
(
dermal
and
oral)
and
clothing
(
dermal
and
oral)
exposures
using
the
exposure
estimates
based
on
5%
residue
transfer.

8.
Aggregate
Risk
Assessment
The
Food
Quality
Protection
Act
amendments
to
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA,
Section
408(
b)(
2)(
A)(
ii))
require
"
that
there
is
a
reasonable
certainty
that
no
harm
will
result
from
aggregate
exposure
to
pesticide
chemical
residue,
including
all
anticipated
24
dietary
exposures
and
other
exposures
for
which
there
are
reliable
information."
Aggregate
exposure
typically
includes
exposures
from
food,
drinking
water,
residential
uses
of
a
pesticide,
and
other
non­
occupational
sources
of
exposure.

The
acute
aggregate
risk
assessment
is
designed
to
provide
estimates
of
risks
likely
to
result
from
exposures
to
the
pesticide
or
pesticide
residues
in
food,
water,
and
from
residential
(
or
other
non­
occupational)
pesticide
uses.
As
previously
mentioned
in
section
six
of
this
document,
"
Residential
Risk
Assessment,"
the
antimicrobial
residential
uses
evaluated
for
TCMTB
have
risks
of
concern
for
residential
handlers
applying
paint
via
airless
sprayer
or
brush
roller;
children
playing
on,
or
mouthing
treated
carpets;
and,
adults
and
children
wearing
treated
textiles/
leather
products.
An
aggregate
assessment
for
short­
and
intermediate­
term
residential
exposures
was
not
conducted,
because
risks
of
concern
were
previously
identified
for
individual
residential
exposure
scenarios.
An
aggregate
assessment
would
only
reflect
the
identified
individual
risks
of
concern
and,
therefore,
was
unnecessary.
There
are
no
long­
term
residential
exposure
scenarios
for
TCMTB.

However,
the
Agency
conducted
both
acute
and
chronic
dietary
aggregate
assessments,
which
considered
food
(
antimicrobial
and
agricultural)
and
drinking
water
(
agricultural
only)
exposures,
for
the
registered
antimicrobial
and
agricultural
uses.

In
the
case
of
TCMTB,
a
cancer
aggregate
assessment
is
not
needed,
as
the
chemical
has
been
classified
by
the
Agency
as
having
"
Possible
Human
Carcinogen."
Because
an
RfD
approach
was
used
to
evaluate
chronic
dietary
risk
and
is
considered
protective
of
any
cancer
risk
concern,
only
the
results
of
the
chronic
analysis
are
given.

a.
Acute
Aggregate
Risk
The
acute
aggregate
risk
assessment
considered
the
95th
percentile
dietary
exposure
(
food
and
drinking
water)
from
the
agricultural
seed
treatment
uses,
as
well
as
the
acute
dietary
exposure
(
food
only)
from
the
antimicrobial
uses
in
pulp
and
paper.
While
it
is
standard
to
use
the
chronic
drinking
water
exposure
estimate
for
acute
aggregate
risk
assessments
this
was
not
done
in
this
case.
Since
the
acute
food
and
drinking
water
exposures
were
combined
into
a
single
exposure
estimate
for
the
acute
dietary
assessment,
this
value
was
used
in
the
aggregate
assessment.
Using
the
acute
drinking
water
estimate
is
a
more
conservative
approach
than
the
standard
method
of
conducting
such
an
assessment.
As
shown
in
Table
9,
the
acute
dietary
aggregate
risk
is
2.5%
of
the
aPAD
for
children
and
less
than
1.3%
of
the
aPAD
for
adults.
These
risk
estimates
are
below
the
Agency's
level
of
concern.
25
Table
9.
TCMTB
Acute
Aggregate
Risk
Estimates
Dose
a
(
mg/
kg/
day)
%
aPADb
Exposure
Scenario
Child
(
15
kg)
Adult
Child
(
15
kg)
Adult
Dietary
Exposure
Agricultural
Seed
Treatment
(
Food
and
Water)
0.004581
0.00243
1.8%
<
1%

Antimicrobial
Uses
Total
Pulp/
Paper/
Adhesive
(
Food)
0.0017
0.00083
0.66%
0.33
Total
Aggregate
Dose
and
Risk
0.00628
0.00328
2.5%
<
1.3%

NA=
Not
applicable
(
a)
Acute
dietary
exposure
for
females
13­
50
years
for
antimicrobials
uses.
(
b)
%
aPAD
=
dietary
exposure
(
mg/
kg/
day)
/
aPAD,
where
aPAD
­=
0.25
mg/
kg/
day
for
all
populations.

b.
Chronic
Aggregate
Risk
The
chronic
aggregate
risk
assessment
considered
average
dietary
exposure
(
food
and
drinking
water)
from
the
agricultural
seed
treatment
uses
of
TCMTB,
as
well
as
dietary
exposure
(
food
only)
from
the
antimicrobial
uses
of
TCMTB
in
pulp
and
paper.
As
shown
in
Table
10,
the
chronic
dietary
aggregate
risk
estimate
of
TCMTB
is
30%
of
the
cPAD
for
children
and
is
13.4%
of
the
cPAD
for
adults.
These
risk
estimates
are
below
the
Agency's
level
of
concern.

Table
10.
TCMTB
Chronic
Aggregate
Risk
Estimates
Dose
a
(
mg/
kg/
day)
%
cPADb
Exposure
Scenario
Child
(
15
kg)
Adult
Child
(
15
kg)
Adult
Dietary
Exposure
Agricultural
Seed
treatment
(
Food
and
Water)
0.002226
0.000888
17%
7%

Antimicrobial
Uses
Total
Pulp/
Paper/
Adhesive
(
Food)
0.0017
0.00083
12.8%
6.44
Total
Aggregate
Dose
and
Risk
0.003926
0.001718
30%
13.4%

NA=
Not
applicable
(
a)
Chronic
dietary
exposure
for
females
13­
50
years
for
antimicrobials
uses.
(
b)
%
cPAD
=
dietary
exposure
(
mg/
kg/
day)
/
cPAD,
where
cPAD
­=
0.013
mg/
kg/
day
for
all
populations.

9.
Occupational
Risk
Workers
can
be
exposed
to
a
pesticide
through
mixing,
loading,
and/
or
applying
a
pesticide,
or
re­
entering
treated
sites.
TCMTB
is
used
as
an
antimicrobial
pesticide
(
e.
g.,
materials
preservative,
industrial
processes
and
water
systems,
wood
preservative
and
paint
application)
and
as
a
seed
treatment.
Potential
occupational
exposure
can
occur
in
various
use
sites,
which
include
commercial/
industrial
premises,
industrial
process
and
water
systems,
from
wood
preservation,
and
from
metal
working
fluid
uses.
26
Occupational
handlers
of
TCMTB
include
handlers
applying
TCMTB
treated
paint
via
airless
sprayer
or
paint
brush/
roller;
handlers
pouring
TCMTB
liquid
preservative
for
paint
preservation,
textile
preservation,
drilling
fluids,
metal
working
fluids
and
small
process
water
systems;
handlers
pumping
(
metering)
liquid
preservative
for
metal
working
fluid,
pulp
and
paper
and
cooling
water
systems,
paint
and
textiles
preservation,
and
small
process
water
systems;
and
wood
preservative
handlers.

For
the
seed­
treatment
use
of
TCMTB,
occupational
handlers
include
workers
in
agricultural
seed
treatment
settings
(
commercial
and
on­
farm
settings)
and
workers
handling
seed
previously
treated
(
post­
application
worker
exposure).

a.
Occupational
Toxicity
The
toxicological
endpoints
used
in
the
occupational
handler
assessment
of
TCMTB
can
be
found
in
Table
6,
"
Residential
and
Occupational
Toxicological
Doses
and
Endpoints
for
TCMTB",
of
this
document.

b.
Occupational
Handler
Exposure
Occupational
risk
for
all
potentially
exposed
populations
is
measured
by
a
Margin
of
Exposure
(
MOE),
which
determines
how
close
the
occupational
exposure
comes
to
a
No
Observed
Adverse
Effect
Level
(
NOAEL)
from
toxicological
studies.
Occupational
risk
is
assessed
for
exposure
at
the
time
of
application
(
termed
"
handler"
exposure).
Application
parameters
are
generally
defined
by
the
physical
nature
of
the
formulation
(
e.
g.,
formula
and
packaging),
by
the
equipment
required
to
deliver
the
chemical
to
the
use
site
and
by
the
application
rate
required
to
achieve
an
efficacious
dose.

The
Agency
evaluated
representative
scenarios
using
maximum
application
rates
as
recommended
on
TCMTB
product
labels.
To
assess
handler
risk,
the
Agency
used
surrogate
unit
exposure
data
from
both
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
Antimicrobial
Exposure
Study
(
USEPA,
1999)
and
the
Pesticide
Handlers
Exposure
Database
(
PHED),
(
USEPA,
1998).
The
duration
of
exposure
to
TCMTB
is
expected
to
be
short­
term
or
intermediate­
term
(
1
day
to
6
months)
for
most
occupational
scenarios.
Wood
preservation
and
metal
working
fluid
uses
were
assumed
to
be
long­
term
exposure
durations.

For
more
information
on
the
assumptions
and
calculations
of
potential
agricultural
and
antimicrobial
risks
of
TCMTB
to
workers,
see
the
Occupational
Exposure
Assessment
(
Sections
9.0­
9.2)
in
the
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
August
1,
2006,
the
antimicrobial
"
Occupational
and
Residential
Exposure
Assessment
for
2­(
Thiocyanomethylthio)
benzothiazole
TCMTB,"
dated
April
19,
2006
and
the
"
TCMTB
[
2­(
Thiocyanomethylthio)
benzothiazole]:
Third
Revision
of
the
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document"
for
the
agricultural
uses
of
TCMTB,
dated
July
27,
2006.
27
Antimicrobial
Use
Inhalation
and
dermal
exposures
to
TCMTB
(
as
an
antimicrobial
pesticide)
were
addressed
for
occupational
populations
for
both
short­
and
intermediate­
term
durations.
The
Agency
used
surrogate
unit
exposure
data
from
the
proprietary
Chemical
Manufacturers
Associated
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999)
and
the
Pesticide
Handlers
Exposure
Database
(
PHED)
to
assess
handler
risks
(
USEPA,
1998).
MOEs
for
material
preservation
of
paints,
textiles,
adhesives
and
metalworking
fluid
were
calculated
using
unit
exposure
values
from
the
cooling
tower
CMA
data­
set
(
USEPA,
1999)
because
exposure
data
were
not
available
for
ungloved
handlers.
Handler
exposures
were
assessed
for
the
application
of
TCMTB­
preserved
paint.

For
the
airless
sprayer
scenario,
PHED
dermal
and
inhalation
unit
exposure
values
for
a
residential
handler
applying
a
pesticide
using
an
airless
sprayer
were
used.
These
unit
un­
gloved
exposure
values
(
79
mg/
lb
a.
i.
for
dermal
and
0.83
mg/
lb
a.
i.
for
inhalation)
represent
a
handler
wearing
short
pants
and
a
short
sleeve
shirt,
with
no
gloves.
It
was
assumed
that
15
gallons
(
or
150
lb/
day,
assuming
paint
has
a
density
of
10
lb/
gal)
of
treated
paint
were
to
be
used
per
day.

For
the
brush/
roller
scenario,
PHED
dermal
and
inhalation
unit
exposure
values
for
a
residential
handler
applying
a
pesticide
using
an
airless
sprayer
were
used.
These
unit
exposure
values
(
230
mg/
lb
a.
i.
for
dermal
and
0.284
mg/
lb
a.
i.
for
inhalation)
represent
a
handler
wearing
short
pants
and
a
short
sleeve
shirt,
with
no
gloves.
It
was
assumed
that
for
the
brush/
roller
paint
applications
2
gallons
(
or
20
lb/
day,
assuming
paint
has
a
density
of
10
lb/
gal)
of
treated
paint
were
to
be
used
per
day.

The
duration
of
exposure
for
most
homeowner
applications
of
paint
is
believed
to
be
best
represented
by
the
short­
term
duration
(
1
to
30
days).
The
reason
that
short
term
duration
was
chosen
to
be
assessed
is
because
the
different
handler
and
post­
application
scenarios
are
assumed
to
be
episodic,
not
daily.
In
addition,
homeowners
are
assumed
to
use
different
products
with
varying
activities,
not
exclusively
TCMTB
treated
products.

The
dermal
and
inhalation
wood
unit
exposure
values
for
wood
preservation
were
based
on
two
replicates
where
the
test
subjects
were
wearing
a
single
layer
of
clothing
and
chemical
resistant
gloves.
Surrogate
unit
exposures
were
taken
from
the
CMA
study
(
USEPA,
1999).
The
quantity
of
the
wood
being
treated
was
derived
from
other
wood
preservative
estimates
(
USEPA,
2004)
for
the
amount
of
wood
slurry
treated
because
no
chemical
specific
data
were
available
for
TCMTB.
It
was
assumed
that
batches
of
wood
slurry
are
treated
in
10,000
gallon
tanks
and
that
eight
batches
of
wood
slurry
are
treated
per
day
(
one
per
hour
for
an
8­
hr
work
shift).
Additionally,
it
was
assumed
that
each
batch
requires
3,000
gallons
of
preservatives
and
the
remainder
volume
of
the
tank
consists
of
wood
slurry
(
7,000
gallons
of
wood
slurry
per
batch).
Wood
chips
have
a
density
of
approximately
380
kg/
m3
(
SIMetric,
2005)
and,
therefore,
the
total
amount
of
wood
slurry
treated
per
day
would
be
178,000
lbs
(
8
batches/
day
*
7,000
gallons/
batch
*
0.003785
m3/
gallon
*
380
kg/
m3
*
2.2
lb/
kg).
The
assumptions
used
for
batch
sizes
and
the
quantity
of
preservative
needed
are
consistent
with
an
assessment
performed
previously
by
the
EPA.
For
this
assessment,
an
application
rate
of
0.003
TCMTB
w/
w
was
used.
28
Based
on
the
antimicrobial
use
patterns
of
TCMTB,
the
exposure
scenarios
in
Table
11
were
assessed:

Table
11.
TCMTB
Antimicrobial
Occupational
Handler
Scenarios
Category
Scenario
Commercial
Institutional
Premises
Airless
sprayer
and
paint
brush/
roller
may
be
used
as
methods
of
application
for
paint
application
of
TCMTB
treated
paint.

Materials
Preservative
Pouring
or
pumping
TCMTB
preservative
into
vats
or
tanks
for
preservation
of
textiles/
leather
products,
paints,
adhesives
and
metal
working
fluid.

Industrial
Processes
and
Water
Systems
Occupational
Handler
Scenarios:

Metered
pumping,
pouring
or
liquid
pumping
TCMTB
into
vats
or
tanks
for
drilling
fluids,
pulp
and
paper,
and
small
process
water
systems/
cooling
towers.

Post­
application
Occupational
Handler
Scenarios:

Exposure
can
occur
after
the
chemical
has
been
incorporated
into
the
cutting
fluid
and
a
machinist
is
using/
handling
this
treated
end­
product.

Wood
Preservative
Occupational
Handler
Scenarios:
 
Blender/
spray
operators
are
workers
that
add
the
wood
preservative
into
a
blender/
sprayer
system
for
composite
wood
via
closed­
liquid
pumping.
 
Diptank
Operators
can
be
in
reference
to
wood
being
lowered
into
the
treating
solution
through
an
automated
process
(
i.
e.,
elevator
diptank,
forklift
diptank).
This
scenario
can
also
occur
in
a
smaller
scale
treatment
facility
in
which
the
worker
can
manually
dip
the
wood
into
the
treatment
solution.
 
Chemical
operators
for
a
spray
box
system
consist
of
chemical
operators,
chemical
assistants,
chemical
supervisors,
and
chemical
captains.
These
individuals
maintain
a
chemical
supply
balance
along
with
flushing
and
cleaning
spray
nozzles.

Post­
application
Occupational
Handler
Scenarios:
 
Graders,
positioned
right
after
the
spray
box,
grade
dry
lumber
by
hand
(
i.
e.
detect
faults).
In
the
DDAC
study,
graders
graded
wet
lumber;
therefore,
the
exposures
to
graders
using
TCMTB
are
worst­
case
scenarios.
 
Millwrights
repair
all
conveyer
chains
and
general
up­
keep
of
the
mill.
 
Clean­
up
crews
perform
general
cleaning
duties
at
the
mill.
 
Trim
saw
operators
operate
the
hula
trim
saw
and
consist
of
operators
and
strappers.
In
the
DDAC
study,
hula
trim
saw
operators
handled
dry
lumber.
 
Construction
workers
install
treated
plywood,
oriented
strand
board,
medium
density
fiberboard,
and
others.

Agricultural
Seed
Treatment
Uses
EPA
has
assessed
the
exposure
to
handlers'
mixing/
loading/
applying
products
containing
TCMTB.
Inhalation
and
dermal
exposure
scenarios
were
addressed
for
occupational
populations
for
both
short­
and
intermediate­
term
exposure
durations.
Occupational
handler
exposure
estimates
were
based
on
surrogate
data
from
the
"
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
(
HED
ExpoSAC)
SOP
#
15:
Amount
of
Seed
Treated
or
Planted
per
29
Day",
which
was
completed
on
March
2,
2004.
Generic
protection
factors
(
PFs)
were
used
to
calculate
exposures
when
data
were
not
available.
For
example,
an
80
percent
protection
factor
was
assumed
for
the
use
of
a
respirator
equipped
with
a
quarter­
face
dust/
mist
filter.
It
was
assumed
that
on­
farm
treaters
and
planters
are
expected
to
have
short­
term
exposure
duration
(
less
than
30
days)
for
all
seed
crops.
It
was
also
assumed
that
personal
protective
equipment
for
on­
nursery
and
commercial
mixer/
loader/
applicators
and
planter
includes
a
single
layer
and
gloves.
Personal
protective
equipment
for
commercial
baggers
and
sewers
includes
baseline
attire
only
­
no
gloves.
Personal
protective
equipment
for
performing
multiple
activities
in
a
commercial
operation
includes
a
single
layer
of
clothing
and
gloves.

Exposure
data
used
for
the
TCMTB
seed
treatment
assessment
are
taken
primarily
from
the
Agency's
recently
developed
seed
treatment
standard
operating
procedure
(
SOPs
for
Seed
Treatment,
6/
1/
03).
The
seed
treatment
SOP
contains
representative
scenarios
for
worker
exposure
associated
with
seed
treatment
facilities
and
planting
treated
seed.
These
scenarios
were
used
to
describe
the
various
types
of
handler
exposures
that
may
occur
from
TCMTB.
Information
from
the
current
labels,
use
and
usage
information,
toxicology
data,
and
exposure
data
were
all
key
components
in
the
development
of
the
exposure
scenarios.
Exposure
estimates
were
taken
from
actual
seed
treatment
studies
and
were
based
on
exposure
factors
associated
with
occupational
handler
scenarios
(
commercial
seed
treatment,
on­
nursery
seed
treatment,
planting
of
treated
seed).
Assessed
application
rates
range
from
0.026
lbs
active
ingredient/
100
lbs
of
seed
to
0.13
lbs
active
ingredient/
100
lbs
of
seed.

Four
categories
of
commercial
seed
treatment
activities
and
two
categories
for
on­
nursery
activities
were
assessed
and
are
shown
in
Table
12.

Table12.
TCMTB
Seed
Treatment
Occupational
Handler
Scenarios
Category
Scenario
Agricultural
Seed
Treatment
Commercial
Seed
Treatment
Scenarios:
(
S­
1)
Loading
and
applying
liquid
formulations
with
commercial
seed­
treatment
equipment.
(
S­
2)
Commercial
sewer
stitching
bags
of
seed.
(
S­
3)
Bagging
and
otherwise
handling
treated
seeds
with
commercial
equipment.
(
S­
4)
Multiple
commercial
seed
treatment
activities.

On­
Nursery
Seed
Treatment
and
Planting
Post
Application
Scenarios:
(
S­
5)
On­
nursery
loading/
applying
seed
treatment.
(
S­
6)
On­
nursery
loading/
planting
previously
treated
seeds.
30
c.
Occupational
Handler
Risk
Summary
Antimicrobial
Use
The
occupational
handler
risk
assessment,
for
the
antimicrobial
use
of
TCMTB,
included
both
inhalation
and
dermal
exposure
scenarios.
The
target
MOE
for
short­
and
intermediate
term­
inhalation
and
dermal
exposures
was
100.
The
target
MOE
for
long­
term
dermal
and
inhalation
exposures
was
300.
All
but
two
of
the
short­
and
intermediate­
term
dermal
and
inhalation
scenarios
assessed
were
not
of
concern
(
MOEs
greater
than
100).
The
following
two
dermal
exposure
scenarios
indicate
risks
of
concern
even
with
the
addition
of
chemical
resistant
gloves:

 
Paint
Application:
Airless
Sprayer
(
ST/
IT
Dermal
MOE
=
6.1
ungloved,
MOE
=
17
gloved)

 
Paint
Application:
Paintbrush
(
ST/
IT
Dermal
MOE
=
30
ungloved,
MOE
=
97
gloved)

Risks
of
concern
were
identified
for
six
use
scenarios
(
paint
preservation
liquid
pour,
paint
preservation
liquid
pump,
textile
preservation
liquid
pour,
textile
preservation
liquid
pump,
cutting
fluid
preservation
liquid
pour,
pulp
and
paper
liquid
pump)
at
the
baseline
level
of
evaluation
(
no
PPE
gloves).
However,
the
dermal
MOEs
are
greater
than
100
with
the
addition
of
PPE
(
gloves).
Therefore,
the
use
of
PPE
gloves
eliminates
all
risks
of
concern
for
these
six
use
scenarios.

The
total
dermal
and
inhalation
MOEs
with
added
PPE
(
gloves)
are
not
of
concern
for
all
but
two
of
the
scenarios
evaluated.
The
following
scenarios
have
remaining
total
dermal
and
inhalation
MOEs
that
are
less
than
100
and
are
of
concern:

 
Paint
Application:
Airless
Sprayer
(
Total
Dermal
and
Inhalation
MOE
=
16)

 
Paint
Application:
Paintbrush
(
Total
Dermal
and
Inhalation
MOE
=
95)

For
further
information
regarding
the
short­
and
intermediate­
term
risks
associated
with
occupational
handlers,
refer
to
Tables
13
and
14.
31
Table
13.
Antimicrobial
Use
Short­
and
Intermediate­
Term
Risks
Associated
with
Occupational
Handlers
ST/
IT
MOE
c
(
Target
MOE
 
100)
Exposure
Scenario
Method
of
Application
Application
Rate
(%
a.
i.
by
weight)
Quantity
Handled/
Treated
per
day
Baseline
Dermala
PPE­
Glove
Dermal
b
Inhalation
TOTAL
MOE
(
dermal
and
inhalation)

Airless
Sprayer
500
lb/
day
6.1
17
180
16
Paint
Application
Paintbrush
50
lb/
day
30
97
5,300
95
Liquid
Pour
2,000
lb/
day
1.2
430
11,000
414
Paint
Preservation
Liquid
Pump
0.015
a.
i.
weight
fraction
10,000
lb/
day
26
1900
19,000
1,727
Liquid
Pour
<
1
220
5,400
211
Textiles/
Leather
Products
Liquid
Pump
0.006
a.
i.
weight
fraction
10,000
lb/
day
64
4,600
46,000
4,182
Liquid
Pour
11
3,000
42,000
2,800
Cutting
Fluid
Liquid
Pump
0.00125
a.
i.
weight
fraction
2,502
lb/
day
1,200
1,800
1.00x105
1,768
ST
=
45.9
lb/
day
ST
=
1000
ST
=
380,000
ST
=
9.40x10­
6
365,235
Drilling
Fluids
Liquid
Pour
IT
=
22.9
lb/
day
IT
=
2,000
IT
=
7.60x105
IT
=
1.90x107
730,769
Pulp
and
Paper
Liquid
Pump
0.00075
a.
i.
weight
fraction
1,000,000
lb/
day
5
510
5,600
467
Liquid
Pour
90
lb/
day
43,000
21,000
3.10x106
20.858
Small
Process
Water
Systems/
Cooling
Tower
Liquid
Pump
0.000009
a.
i.
weight
fraction
180,000
lb/
day
2,400
13,000
1.60x105
12,023
ST
=
short­
term;
IT
=
intermediate­
term
a
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.
b
PPE
Dermal
with
gloves:
baseline
dermal
plus
chemical­
resistant
gloves.
c
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
[
Where
ST/
IT
NOAEL
=
25
mg/
kg/
day
for
dermal
and
16
mg/
kg/
day
for
inhalation].

Table
14
provides
short­
and
intermediate­
term
doses
and
MOEs
for
workers
adding
TCMTB
preservative
to
wood
slurry.
When
wearing
single
layer
clothing
and
chemical
resistant
gloves,
all
MOEs
are
above
the
target
MOE
of
100
for
ST/
IT
dermal
and
inhalation
and
above
300
for
LT
dermal
and
inhalation
exposures
and,
therefore,
are
not
of
concern.
32
Table
14.
Short­,
Intermediate­
and
Long­
term
Risks
Associated
with
Wood
Preservative
Blender/
Spray
Operators
Absorbed
Daily
Dosee
(
mg/
kg/
day)
MOEf
Dermal
Inhalation
Total
MOE
Dermal
Unit
Exposurea
(
mg/
lb
ai)
Inhalation
Unit
Exposureb
(
mg/
lb
ai)
App.
Ratec
(
fraction
ai
in
solution/

day)
Wood
Slurry
Treatedd
(
lb/
day)
Dermal
Inhal.
ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
Occupational
Handler
0.00629
4.03x10­
4
0.00300
1.78x105
0.0480
0.00307
520
5200
1200
478
364
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term.
a.
Dermal
unit
exposure:
Single
layer
clothing
with
chemical
resistant
gloves.
b.
Inhalation
unit
exposure:
Baseline.
c.
The
maximum
application
rate
for
the
"
immersion"
application
method
is
a
solution
containing
0.3%
a.
i.
d.
Wood
slurry
treated
=
(
8
batches/
day
*
7,000
gallons/
batch
*
0.003785
m3/
gallon
*
380
kg/
m3
*
2.2
lb/
kg)
e.
Absorbed
Daily
Dose
=
unit
exposure
(
mg/
lb
ai)
x
App
Rate
(
fraction
ai/
day)
x
Quantity
treated
(
lb/
day)
/
BW
(
70
kg)
f.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
dermal
ST/
IT/
LT
NOAEL
=
25
mg/
kg/
day,
ST/
IT
inhalation
NOAEL
=
16
mg/
kg/
day,
and
LT
inhalation
NOAEL
=
3.8
mg/
kg/
day].
Target
MOE
is
100
for
ST/
IT
dermal
exposures
and
300
for
LT
dermal
and
100
for
ST/
IT
and
300
for
LT
inhalation
exposures.

Agricultural
Seed
Treatment
Uses
The
occupational
handler
assessments
were
conducted
using
increasing
levels
of
protection.
The
Agency
typically
evaluates
all
exposures
with
minimal
protection
and
then
considers
additional
protective
measures
using
a
tiered
approach
(
going
from
minimal
to
maximum
levels
of
protection)
in
an
attempt
to
obtain
an
adequate
MOE.
The
lowest
tier
is
represented
by
the
baseline
clothing
scenario
(
i.
e.,
single
layer
clothing,
socks
and
shoes),
followed
by,
if
MOEs
are
of
concern,
increasing
levels
of
risk
mitigation
such
as
personal
protective
equipment
(
PPE)
and
engineering
controls
(
EC).

The
occupational
handler
risk
assessment
for
the
agricultural
seed
treatment
use
of
TCMTB
included
both
inhalation
and
dermal
exposures.
The
target
MOE
for
both
the
inhalation
and
dermal
exposures
was
100.
Scenarios
with
an
MOE
less
than
100
indicate
a
risk
of
concern.
The
Agency
evaluated
occupational
risks
to
workers
that
use
TCMTB
as
a
fungicide
for
treating
seeds
in
commercial
and
on­
nursery/
on­
farm
settings.

For
commercial
seed
treatment,
all
individual
dermal
and
inhalation
MOEs
met
or
exceeded
the
target
MOE
of
at
the
baseline
level
of
mitigation
(
single
layer
of
clothing
with
gloves
and
no
respirator).
MOEs
were
above
the
target
of
100
for
the
combined
inhalation
and
dermal
exposure
scenarios
at
the
baseline
level
of
mitigation
(
single
layer
of
clothing
with
gloves
and
no
respirator).
Please
refer
to
Tables
15
and
16
for
further
details
regarding
the
estimated
worker
exposures
and
risks
from
commercial
and
on­
nursery
seed
treatment.
33
Table
15.
Estimated
Worker
Exposure
and
Risk
from
Commercial
Seed
Treatment
Short­
and
Intermediate­
term
Risk
Estimates
Crop
Exposure
Scenario
Application
Rate
(
lb
ai/
100
lb)
a
Amount
Handled
per
Day
(
lb
ai/
day)
b
Dermal
MOE
(
Target
MOE 
100)
Inhalation
MOE
(
Target
MOE 
100)
Total
MOE
c
(
Target
MOE 
100)
Level
of
Mitigationc
Loader/
Applicator
410
18,000
400
SL,
G+
NR
Sewer
1,500
26,000
1,400
SL
+
NR
Bagger
1,000
37,000
970
SL
+
NR
Barley,
Oat,
Rice,
Wheat
Seeds
Multiple
Activities
0.026
187
220
3,700
210
SL,
G+
NR
Loader/
Applicator
370
16,000
360
SL,
G+
NR
Sewer
1,400
23,000
1,300
SL
+
NR
Bagger
920
34,000
900
SL
+
NR
Cotton
Seeds
Multiple
Activities
0.13
208
200
3,400
190
SL,
G+
NR
Loader/
Applicator
260
11,000
250
SL,
G+
NR
Sewer
960
17,000
910
SL
+
NR
Bagger
650
24,000
630
SL
+
NR
Safflower
Seeds
Multiple
Activities
0.041
294
140
2,400
130
SL,
G+
NR
Loader/
Applicator
2,100
91,000
2,100
SL,
G+
NR
Sewer
7,800
130,000
7,400
SL
+
NR
Bagger
5,300
190,000
5,200
SL
+
NR
Sugar
Beet
Seeds
Multiple
Activities
0.041
36
1,200
19,000
1,100
SL,
G+
NR
ND
=
No
Data;
NF
=
Not
Feasible;
NR=
No
respirator
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
TCMTB
b
Amount
handled
per
day
calculated
from
the
maximum
application
rate
and
the
lbs
of
seed
treated
or
planted/
day
and:
for
barley,
rice,
safflower,
and
wheat
seed
­
718000
lb/
day;
for
cotton
seed
 
160000
lb/
day;
and
sugar
beet
seed
 
88000
lb/
day.
c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.
Baseline
Inhalation:
no
respirator.
SL,
G
=
Single
layer
w/
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.
DL,
G
=
Double
layer
w/
gloves
is
coveralls
worn
over
long­
sleeve
shirt
and
long
pants,
plus
Table
16.
Estimated
Worker
Exposure
and
Risk
from
On­
nursery
Seed
Treatment
Unit
Exposures
Short­
and
Intermediate­
term
MOEs
Baseline
Personal
Protective
Equipment
Engineering
Controls
Baseline
Personal
Protective
Equipment
Dermal
(
mg/
lb
ai)
Inhalation
(
ug/
lb
ai)
Dermal
Inhalation
Crop
Acres
treated/
day
App
Rate
(
lb
ai/
100
lb)
a
Amount
Handled
per
dayb
(
lb
ai/
day)
Dermalc
(
mg/
lb
ai)
Inhalationd
(

g/
lb
ai)
SL
w/
glovese
80%
Rf
90%
Rg
Dermalh
(
mg/
lb
ai)
Inhalationi
(
ug/
lb
ai)
Inhalation
SL
w/
gloves
80%
R
90%
R
LOADING/
APPLYING
LIQUID
SEED
TREATMENTS
Cotton
125
0.051
0.64
NDj
ND
=
No
Data
D
On­
nursery
seed
treatment
with
liquid
formulations
is
generally
done
with
automated
equipment,
essentially
miniature
versions
of
commercial
treaters.
34
d.
Occupational
Post­
application
Risk
Summary
Occupational
post­
application
exposures
may
occur
from
both
antimicrobial
and
agricultural
use
scenarios.
Occupational
handlers
may
be
exposed
to
TCMTB
by
handling
treated
wood;
handling
metal
working/
cutting
fluids;
and
loading/
planting
previously
treated
seeds.

Antimicrobial
Use
TCMTB
is
used
in
products
that
are
intended
to
preserve
wood
through
non­
pressure
treatment
methods.
It
can
be
applied
as
a
sapstain
control
to
freshly­
cut
wood,
incorporated
into
particle
board,
or
used
to
treat
wood
chips.
When
used
as
a
sapstain
control,
the
product
may
be
dipped,
sprayed,
or
impregnated
into
the
wood
via
pressure
treatment
(
up
to
0.3%
a.
i.
solution).
When
used
in
particle
board,
the
pesticide
is
incorporated
into
the
resin
or
binding
agent
(
0.3%
a.
i.,
based
on
dry
weight
of
wood).
As
very
little
chemical
specific
data
were
available
regarding
typical
exposures
to
TCMTB
as
a
wood
preservative,
surrogate
data
were
used
to
estimate
exposure
risks.
The
blender/
spray
operator
position
was
assessed
using
CMA
unit
exposure
data
and
the
remaining
handler
and
post­
application
positions
were
assessed
using
data
from
a
DDAC
study
(
Bestari
et
al.,
1999).

Post­
application
exposures
to
chemical
operators,
graders,
millwrights,
trim
saw
operators,
and
clean­
up
crews
were
assessed
using
surrogate
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
The
DDAC
study
examined
individuals'
exposure
to
DDAC
while
working
with
antisapstains
and
performing
routine
tasks
at
11
sawmills/
planar
mills
in
Canada.
Dermal
and
inhalation
exposure
monitoring
data
were
gathered
for
each
job
function
of
interest
using
dosimeters
and
personal
sampling
tubes.
Dosimeters
and
personal
air
sampling
tubes
were
analyzed
for
DDAC.
Exposure
data
for
individuals
performing
the
same
job
functions
were
averaged
together
to
determine
job
specific
averages.
Monitoring
was
conducted
using
2
trim
saw
workers,
13
grader
workers,
11
chemical
operators,
3
millwrights,
and
6
clean­
up
staff.

Exposures
to
diptank
operators
were
also
assessed
using
surrogate
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
The
diptank
scenario
assessment
was
conducted
differently
than
for
the
other
job
functions
because
the
concentration
of
DDAC
in
the
diptank
solution
was
provided.
The
exposure
data
for
diptank
operators
wearing
gloves
were
converted
into
unit
exposures
in
terms
of
mg
a.
i.
for
each
1%
of
concentration
of
the
product.
Dermal
and
inhalation
unit
exposures
were
2.99
and
0.046
mg/
1%
solution,
respectively.
The
air
concentrations
presented
in
the
DDAC
study
were
converted
to
unit
exposures
using
an
inhalation
rate
of
1.0
m3/
hr
(
light
activity)
and
a
sample
duration
of
8
hrs/
day.

There
are
no
risks
of
concern
for
the
short­,
intermediate­
or
long­
term
occupational
handler
dermal
and
inhalation
wood
preservative
exposure
scenarios
(
ST/
IT
dermal
and
inhalation
MOEs
>
100;
LT
dermal
and
inhalation
MOEs
>
300).
The
combined
dermal
and
inhalation
scenarios
also
met
or
exceeded
the
target
MOE
of
100
when
handlers
were
wearing
short
sleeve
shirts,
cotton
work
trousers,
and
cotton
glove
dosimeter
gloves
under
chemical
resistant
gloves
and,
therefore,
are
not
of
concern.
35
Table
17.
Short­,
Intermediate­
and
Long­
Term
Exposures
and
Risk
for
Occupational
Handlers
for
Wood
Preservative
Use
MOEsc(
Target
MOE
 
100
for
ST/
IT,
300
for
LT)

Dermal
Inhalation
TOTAL
MOE
(
dermal
and
inhalation)
Exposure
Scenarioa
(
number
of
volunteers)

ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
Blender/
Spray
Operator
(
b)
520
5,200
1,200
478
364
Chemical
Operator
(
n=
11)
48,000
1.10x107
2.50x106
47,790
47,095
Grader
(
n=
13)
1.50x105
1.00x107
2.40x106
147,783
141,176
Trim
Saw
(
n=
2)
3.40x105
4.90x106
1.20x106
317,940
264,935
Millwright
(
n=
3)
36,000
5.20x106
1.20x106
35,752
34,951
Clean­
Up
(
n=
6)
8,400
4.90x105
1.20x105
8,258
7,850
Diptank
Operator
1,900
8.10x104
19,000
1,856
1,727
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term
a.
Unless
specified,
the
exposure
scenario
represents
a
worker
wearing
short
sleeve
shirts,
cotton
work
trousers,
and
cotton
glove
dosimeter
gloves
under
chemical
resistant
gloves.
Volunteers
were
grouped
according
to
tasks
they
conducted
at
the
mill.
b.
Single
layer
clothing
with
chemical
resistant
c
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
ST/
IT/
LT
dermal
NOAEL
=
25
mg/
kg/
day,
ST/
IT
NOAEL
for
inhalation
is
16
mg/
kg/
day
and
LT
NOAEL
for
inhalation
is
3.8
mg/
kg/
day].
Target
MOE
is
100
for
ST/
IT
dermal
and
inhalation
exposures,
300
for
LT
dermal
and
inhalation
exposure.

Not
enough
data
exists
to
estimate
the
amount
of
exposure
associated
with
construction
workers
who
install
treated
wood.
In
particular,
values
for
the
transfer
coefficient
associated
with
a
construction
worker
handling
the
wood
could
not
be
determined.
It
is
believed
that
the
construction
worker
using
a
trim
saw
will
have
larger
dermal
and
inhalation
exposures
than
the
installer,
due
to
the
amount
of
sawdust
generated
and
the
greater
amount
of
hand
contact
that
would
be
necessary
to
handle
the
wood
when
using
a
saw
compared
to
installing
the
wood.
Because
the
dermal
and
inhalation
MOE's
are
well
above
the
target
of
100
for
trim
saw
operators
and
handler
exposure
is
expected
to
be
greater
for
trim
saw
operation,
risks
of
concern
are
not
anticipated
for
construction
workers
installing
treated
wood.

Occupational
workers
may
also
be
exposed
to
TCMTB
when
handling
previously
treate
metal
working/
cutting
fluids.
For
the
metal
working/
cutting
fluids
scenario,
dermal
exposure
estimates
were
derived
using
the
two­
hand
immersion
model
from
ChemSTEER.
A
screening
level
intermediate­
and
long­
term
inhalation
exposure
estimate
for
treated
metal
working
fluids
was
developed
using
the
OSHA
Permissible
Exposure
Limit
(
PEL)
for
oil
mist.
Post­
application
dermal
and
inhalation
exposure
occurs
after
the
chemical
has
been
incorporated
into
the
metal
working
fluid
and
a
machinist
is
using/
handling
this
treated
end­
product.
It
was
assumed
that
a
machinist
is
exposed
to
the
metal
working
fluid
8
hours
a
day,
for
5
days
a
week
and
that
the
body
weight
of
an
adult
is
70
kg
(
US
EPA1997).

For
the
metal
working
fluid
scenario,
all
combined
dermal
and
inhalation
scenarios
met
or
exceeded
the
target
MOE
of
100
and,
therefore,
are
not
of
concern.
However,
there
are
human
incident
data
related
to
the
occupational
handler
post­
application
use
of
TCMTB
as
an
antimicrobial
product.
This
and
other
data
indicate
dermal
irritation
from
exposure
to
TCMTB
and
that
TCMTB
is
a
dermal
sensitizer
(
toxicity
category
I
for
eye
irritation
and
toxicity
category
II
for
dermal
irritation).
36
Table
18.
Short­,
Intermediate
and
Long­
Term
Risks
Associated
with
Post­
application
Exposure
to
Metal
Working
Fluids
Treated
with
TCMTB
(
Machinist)

Dermal
Inputs
Inhalation
Inputs
MOE
(
Target
MOE
 
100
for
ST/
IT,
300
for
LT)
c,
d
Dermal
MOE
Inhalation
MOE
TOTAL
MOE
(
dermal
and
inhalation)
Weight
Fraction
a.
i.
in
Fluid
Hand
Surface
Area
(
cm2)
Film
thickness
(
mg/
cm2)
Frequency
(
event/
day)
OSHA
PEL
(
mg/
m3)
Inhal.
rate
(
m3/
hr)
Exposure
Duration
(
hrs/
day)

ST/
IT/
LT
ST/
IT
LT
ST/
IT
LT
0.00125
840
1.75
1
5
1
8
950
22000
5300
910
806
a
Absorbed
Dermal
Daily
Dose
(
mg/
kg/
day)
=
[
fraction
a.
i.
in
treated
fluid
*
hand
surface
area*
film
thickness
(
mg/
cm2)*
Frequency
(
event/
day)]
/
Body
weight
(
70
kg).
b
Absorbed
Inhalation
Daily
Dose
(
mg/
kg/
day)
=
fraction
a.
i.
in
treated
fluid
*
OSHA
PEL
(
mg/
m3)
*
Inhalation
rate
(
m3/
hr)
*
exposure
duration
(
hr/
day)
/
body
weight
(
70
kg)
c
Dermal
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
(
mg/
kg/
day)
[
Where:
ST/
IT/
LT
dermal
NOAEL
=
25
mg/
kg/
day].
d
Inhalation
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
(
mg/
kg/
day)
[
Where:
ST/
IT
inhalation
NOAEL
=
16
mg/
kg/
day
and
LT
Inhalation
NOAEL
=
3.8
mg/
kg/
day].

Agricultural
Seed
Treatment
Use
For
the
agricultural
seed
treatment
use,
the
post­
application
occupational
risk
assessment
considered
exposure
to
TCMTB
from
entering
nurseries
after
plants
had
been
treated.
Onnursery
seed
treatment
scenarios
were
assessed
for
loading/
planting
previously
treated
seeds.

Dermal
and
inhalation
exposures
were
evaluated
in
the
post­
application
worker
assessment.
For
the
on­
nursery
seed
treatment
scenarios,
individual
dermal
and
inhalation
MOEs
are
all
greater
than
the
target
of
100
without
the
use
of
PPE,
and
thus
are
not
of
concern.
The
combined
dermal
and
inhalation
on­
nursery
seed
treatment
MOEs
are
also
all
above
the
target
of
100
with
PPE,
single
layer
baseline
attire
and
chemical­
resistant
gloves.
Table
19
list
the
worker
risk
estimates
for
the
post­
application
on­
nursery
seed
treatment.
37
Table
19.
Estimated
Worker
Exposure
and
Risk
from
On­
Nursery
Seed
Treatment
(
Postapplication

Short­
and
Intermediate­
term
Risk
Estimates
Crop
Acres
treated/
day
App
Rate
(
lb
ai/
100
lb)
a
Amount
Handled
per
dayb
(
lb
ai/
day)
Inhalation
MOE
(
Target
MOE 
100)
Dermal
MOE
SL
w/
gloves
(
Target
MOE 
100)
Total
MOE
(
Target
MOE 
100)
Level
of
Mitigation
LOADING/
PLANTING
PREVIOUSLY
TREATED
SEEDS
Barley
35
0.026
0.64
360,000
7,700
7,500
SL,
G
+
NR
Beet;
Sugar
80
0.041
0.26
1,300,000
27,000
26,000
SL,
G
+
NR
Cotton
200
0.13
4.68
70,000
1,500
1,500
SL,
G
+
NR
Oats
200
0.026
6.66
49,000
1,100
1,100
SL,
G+
NR
Rice
200
0.026
7.80
42,000
900
880
SL,
G+
NR
Safflower
80
0.041
3.28
100,000
2,100
2,100
SL,
G
+
NR
Wheat
200
0.026
7.80
42,000
900
880
SL,
G+
NR
ND
=
No
Data;
NF
=
Not
Feasible;
NR
=
no
respirator
SL,
G
=
Single
layer
w/
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.

a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
TCMTB
b
Amount
handled
per
day
calculated
from
the
acres
treated/
day
and
the
maximum
lb
of
seed
planted
per
acre.
c
On­
nursery
seed
treatment
with
liquid
formulations
is
generally
done
with
automated
equipment,
essentially
miniature
versions
of
commercial
treaters.
d
Amount
handled
per
day
calculated
from
the
maximum
application
rate
and
the
lbs
of
seed
treated
or
planted/
day
for:
barley,
rice,
safflower
and
wheat
seed­
718000
lb/
day;
for
cotton
seed
160000
lb/
day;
and
for
sugar
beet
seed
88000
lb/
day.

9.
Human
Incident
Data
The
Agency
reviewed
available
sources
of
human
incident
data
for
incidents
relevant
to
TCMTB.
EPA
consulted
the
following
sources
of
information
for
human
poisoning
incidents
related
to
TCMTB
use:
(
1)
OPP
Incident
Data
System
(
IDS)
­
The
Office
of
Pesticide
Programs
(
OPP)
Incident
Data
System
contains
reports
of
incidents
from
various
sources,
including
registrants,
other
federal
and
state
health
and
environmental
agencies
and
individual
consumers,
submitted
to
OPP
since
1992;
(
2)
California
Department
of
Pesticide
Regulation
(
1982­
2004)
 
The
California
Department
of
Pesticide
Regulation
pesticide
poisoning
surveillance
program
consists
of
reports
from
physicians
of
illness
suspected
of
being
related
to
pesticide
exposure
since
1982;
(
3)
National
Pesticide
Information
Center
(
NPIC)
­
NPIC
is
a
toll­
free
information
service
supported
by
OPP
That
provides
a
ranking
of
the
top
200
active
ingredients
for
which
telephone
calls
were
received
during
calendar
years
1984­
1991.
38
For
TCMTB,
dermal,
inhalation,
ocular
and
oral
exposures
were
reported.
Most
of
the
incidents
reported
were
irritation
type
reactions.
The
primary
routes
of
exposure
for
these
incidents
were
dermal
and
inhalation;
though
oral
ingestion
incidents
were
reported.
The
most
common
symptoms
reported
for
each
exposure
route
are
as
follows:

 
Dermal
exposure:
skin
irritation/
burning,
rash,
itching,
skin
discoloration/
redness
and
blistering.

 
Inhalation
exposure:
respiratory
irritation/
burning,
irritation
to
mouth/
throat/
nose,
coughing/
chocking,
shortness
of
breath
and
sore
throat.

 
Ocular
exposure:
eye
irritation/
burning,
eye
pain
and
swelling
of
eyes.

 
Ingestion/
oral
exposure:
irritation
to
mouth/
throat/
nose,
abdominal
pain,
kidney
failure,
hypothermia
and
loss
of
consciousness.

In
addition,
a
cross­
sectional
study
was
conducted
to
observe
the
health
effects
associated
with
the
use
of
TCMTB
in
the
British
Columbia
sawmill
industry
(
Teschke,
1992).
Workers
in
five
costal
sawmills
were
asked
to
complete
a
self­
administered
questionnaire
about
symptoms
they
experienced
after
fungicide
exposure
and
about
injuries
commonly
reported
in
sawmills.
The
reported
symptoms
related
to
TCMTB
consistently
included
dry
skin
around
the
eyes,
blood­
stained
mucus
from
the
nose,
nose
bleed,
peeling
skin,
burning
or
itching
skin,
and
skin
redness
or
rash.

B.
Environmental
Risk
Assessment
A
summary
of
the
Agency's
environmental
risk
assessment
is
presented
below.
TCMTB
has
several
registered
use
sites
that
could
result
in
environmental
exposures.
Indoor
uses
were
not
assessed
as
the
Agency
does
not
anticipate
exposure,
given
the
current
use
patterns
of
TCMTB.
The
following
risk
characterization
is
intended
to
describe
the
magnitude
of
the
estimated
environmental
risks
for
TCMTB
use
sites
and
any
associated
uncertainties.

For
a
detailed
discussion
of
all
aspects
of
the
environmental
risk
assessment,
refer
to
the
Environmental
Risk
Assessment
(
Section
10.1)
in
the
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
August
1,
2006;
the
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Ecological
Hazard
and
Environmental
Risk
Assessment
Chapter­
Revised,"
dated
August
1,
2006;
and
the
"
Environmental
Fate
Assessment
of
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
March
30,
2006.

1.
Environmental
Fate
and
Transport
The
environmental
fate
assessment
for
TCMTB
was
based
on
guideline
data
required
by
the
Agency
for
an
environmental
fate
assessment.
These
studies
were
submitted
by
the
technical
registrant.
However,
not
all
of
these
studies
fulfill
guideline
requirements.
For
additional
39
information,
please
refer
to
the
"
Environmental
Fate
Assessment
of
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
March
30,
2006.
Several
metabolites
are
formed
during
the
biotic
degradation
of
TCMTB,
including
2­
benzothiazolesulfonic
acid
(
BTSA)
and
2­
mercaptobenzothiazole
(
2­
MBT).
BTSA
is
not
of
toxicological
concern
because
it
has
negligible
toxicity
and
is
completely
excreted.
2­
MBT
is
generally
less
toxic
than
parent
TCMTB;
therefore,
the
environmental
risk
assessment
was
conducted
for
TCMTB
only.
Please
note
that
although
the
environmental
assessment
does
not
include
2­
MBT
for
the
reasons
stated
above,
2­
MBT
was
included
in
the
drinking
water
assessment
as
a
conservative
approach
to
conducting
the
assessment.

An
assessment
of
the
submitted
guideline
studies
indicates
the
hydrolysis
of
TCMTB
to
be
pH
dependent.
TCMTB
is
hydrolytically
stable
under
abiotic
and
buffered
conditions
at
pH
5
and
slowly
degrades
at
pH
7.
Under
more
alkaline
conditions,
hydrolysis
proceeds
more
rapidly
with
a
calculated
half­
life
ranging
from
1.8
to
2.1
days.
Photolytically,
TCMTB
degrades
in
pH
5
buffered
aqueous
solutions
with
a
calculated
half­
life
of
1.5
hours.
Based
on
its
degradation
in
the
environment,
TCMTB
is
not
likely
to
pose
a
concern
for
surface
water
run­
off.

Aquatic
metabolism
under
aerobic
and
anaerobic
conditions,
as
well
as
aerobic
soil
metabolism,
are
major
routes
of
dissipation
for
TCMTB.
TCMTB's
calculated
degradation
halflife
in
flooded
lake
sediment
is
6.9
days;
however,
the
apparent
half­
life
occurs
between
2
and
4
days.
Similarly,
TCMTB
shows
a
tendency
of
degrading
anaerobically
in
flooded
sediment
within
2.7
days.
Under
aerobic
conditions
in
sandy
loam
soil,
a
representative
agricultural
soil,
TCMTB
degrades
with
a
calculated
half­
life
of
1.4
days.
Because
of
the
biodegradation
in
water
and
soils,
TCMTB
is
not
likely
to
contaminate
surface
and
ground
waters.

TCMTB's
tendency
to
bind
with
agricultural
soils
varies
according
to
soil
type.
TCMTB
is
mobile­
very
mobile
in
various
soils;
however,
because
of
its
tendency
to
biodegrade
in
water
and
soils,
TCMTB
is
not
likely
to
contaminate
surface
and
ground
waters.
TCMTB
is
very
mobile
in
clay
loam,
sand,
and
sandy
loam
soil,
and
mobile
in
clay
and
silt
loam
soil.
Kds
are
3.5
for
clay
loam
soil,
0.99
for
sand
soil,
9.9
for
sandy
loam
soil,
22.1
for
clay
soil,
and
62.7
for
silt
loam
soil.
There
may
be
a
water/
sediment
partitioning
issue
and
an
acute
adverse
impact
on
benthic
organisms.
However,
TCMTB
degrades
fairly
rapidly
in
freshwater
and
soils
and
the
impacts
may
be
short­
lived.

Additional
information
on
the
aqueous
availability
of
TCMTB
from
treated
wood,
indicates
that
the
use
of
TCMTB
as
a
wood
preservative
may
result
in
minimal
releases
to
the
environment.
Nevertheless,
the
Agency
conducted
modeling
to
estimate
TCMTB
concentrations
in
surface
water
from
the
antisapstain
use.
Based
on
conservative
assumptions,
the
Agency
estimated
runoff
concentrations
that
range
from
8.5
to
32.7
ppb.
40
a.
Bioaccumulation
in
Aquatic
Organisms
Bioconcentration
testing
was
conducted
for
TCMTB.
Results
from
this
study
conducted
with
fish
indicate
that
the
bioaccumulation
potential
of
TCMTB
is
minimal
and,
therefore,
not
of
concern
to
the
Agency.

2.
Ecological
Risk
The
Agency's
ecological
risk
assessment
compares
toxicity
endpoints
from
ecological
toxicity
studies
to
estimated
environmental
concentrations
based
on
environmental
fate
characteristics
and
pesticide
use
data.
A
summary
of
the
submitted
data
is
provided
below.

a.
Environmental
Toxicity
Available
data
indicate
that
TCMTB
is
slightly
toxicity
to
birds
on
an
acute
oral
basis
and
subacute
dietary
basis.
Because
birds
are
not
expected
to
come
into
contact
with
TCMTB
on
a
chronic
basis,
avian
reproduction
studies
were
not
required
for
TCMTB.

Based
on
the
results
of
mammalian
studies
conducted
to
meet
human
toxicity
data
requirements,
TCMTB
exhibits
low
acute
oral
and
dermal
toxicity
(
toxicity
category
III);
however,
it
is
highly
irritating
to
the
eyes
and
skin
(
toxicity
category
I
and
II,
respectively).
TCMTB
is
also
considered
to
be
highly
toxic
via
the
inhalation
route
of
exposure
(
toxicity
category
I).
TCMTB
is
a
dermal
sensitizer.

On
an
acute
basis,
TCMTB
is
very
highly
toxic
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
and
estuarine/
marine
invertebrates.
TCMTB
is
generally
more
toxic
then
its'
degradate,
2­
MBT,
and
therefore,
only
TCMTB
was
evaluated
in
the
risk
assessment.
Published
literature
reports
(
MRID#
424053­
01)
indicate
that
TCMTB
may
cause
sublethal
effects
in
fish,
which
could
result
in
an
increase
in
predation
and
a
decreased
ability
to
survive.
These
studies
demonstrate
that
exposure
to
TCMTB
at
levels
of
8­
10
ppb
cause
gill
damage
and
behavioral
changes,
which
can
severely
reduce
the
ability
of
fish
to
survive
in
the
wild
(
Chew.,
Proceedings
of
the
Seventeenth
Annual
Aquatic
Toxicity
Workshop
Vol.
1).
The
toxicity
values
used
in
the
TCMTB
ecological
risk
assessment
(
8.7
Mg/
L)
are
comparable
to
the
levels
described
in
the
published
literature
where
sublethal
effects
occur.
Therefore,
the
TCMTB
risk
assessment
is
protective
of
these
sublethal
effects.

A
summary
of
submitted
acute
ecological
toxicity
data
for
TCMTB
and
2­
MBT
along
with,
avian
sub­
acute
dietary
toxicity
data,
chronic
freshwater
fish
toxicity
data
and
aquatic
plant
toxicity
data
for
TCMTB
are
provided
in
Tables
20,
21,
22
and
23,
respectively.
41
Table
20.
Acute
Ecological
Toxicity
for
TCMTB
and
2­
MBT
Species
Chemical
%
active
ingredient
(
ai)
Endpoint
Toxicity
Category
(
TGAI)
Other
Effects
Noted
Reference/
Status
Birds
TCMTB
80.4%
LD50
=
660
mg/
kg
NOEL
<
292
mg/
kg
Slightly
toxic
Signs
of
toxicity
and
reduction
of
body
weight
and
feed
consumption
at
292
mg/
kg
MRID:
41780901
(
Campbell
1991)/
Acceptable
Northern
bobwhite
(
Colinus
virginianus)

2­
MBT
98.2%
LD50
>
2150
mg/
kg
NOEL
<
1000
mg/
kg
Practically
non­
toxic
Some
evidence
of
dose­
related
abnormalities
upon
gross
necropsy
(
friable
livers,
resorbed
eggs,
fluid­
filled
sacs
in
abdomen)
MRID:

42267101
(
Pedersen
end
Helsten
1992a)/

Acceptable
Mammals
Laboratory
rat
(
Rattus
norvegicus)
TCMTB
80%
ai
LD50=
750
mg/
kg
Moderately
toxic
41583801/
Acceptable
Freshwater
Fish
TCMTB
90%
96hr
static
LC50
=

55.2
ug/
L
(
ppb)
Very
highly
toxic
None
reported
TN
2437
(
USEPA
1980)/
Supplemental
TCMTB
80.4%
96hr
flow
through
LC50
=
20.91
ug/
L
(
ppb)
Very
highly
toxic
NOEC
=
8.7
µ
g/
L
(
ppb)
due
to
mortality
and
lethargy
and
loss
of
equilibrium
in
surviving
fish
at
higher
levels
41818101
(
Machado
1991b)/
Acceptable
Rainbow
trout
Oncorhynchusmykiss)

TCMTB
75%
96hr
static
LC50
=

29
ug/
L
(
ppb)
Very
highly
toxic
Loss
of
equilibrium
and
lying
on
sides
observed
ACC+
0916
24
(
Knott
and
Woodard
1968b)/
Supplemental
TCMTB
90%
96hr
static
LC50
=

32
ug/
L
(
ppb)
Very
highly
toxic
None
reported
TN
2432
(
USEPA
1979)/
Supplemental
Bluegill
sunfish
(
Lepomis
macrochirus)

TCMTB
80.4%
96hr
flow
through
LC50
=
8.7
ug/
L
Very
highly
toxic
NOEC
=
5.1
µ
g/
L
(
ppb)
due
to
signs
of
toxicity
at
41804201
(
Machado
1991a)/
Acceptable
42
Species
Chemical
%
active
ingredient
(
ai)
Endpoint
Toxicity
Category
(
TGAI)
Other
Effects
Noted
Reference/
Status
(
ppb)
higher
levels
TCMTB
75%
96hr
static
LC50
=

47
ug/
L
(
ppb)
Very
highly
toxic
Loss
of
equilibrium
and
lying
on
sides
observed
ACC#
091624
(
Knott
and
Woodard
1968b)/

Supplemental
Rainbow
trout
Oncorhynchus
mykiss)
2­
MBT
98.2%
96
hr
static
LC50
=
730
ug/
L
(
ppb)
Very
highly
toxic
NOEC
=
310
µ
g/
L
(
ppb)
due
to
mortality
at
higher
treatment
levels
42232201
(
Collins
1992)/
Acceptable
Freshwater
Invertebrates
TCMTB
90%.
48­
hr.
static
EC50
=
23
ug/
L
(
ppb)
Very
highly
toxic
TN
2427
(
USEPA
1979)/

Supplemental
TCMTB
80.4%
48­
hr.
flow
through
EC50
=
22
ug/
L
(
ppb);
NOEC
=
8.7
ug/
L
(
ppb)
Very
highly
toxic
41838201
(
McNamara
1991)/
Acceptable
Waterflea
(
Daphnia
magna)

2­
MBT
100%
48­
hr.
static
EC50
=
2,900
ug/
L
(
ppb)
Moderately
toxic
42226001
(
Collins
1992b)/
Acceptable
Estuarine/
Marine
Fish
Sheepshead
minnow
(
Cyprinodon
variegates)
TCMTB
80%
96
hr.
static
LC50
=
60
ug/
L
(
ppb)
Very
highly
toxic
40363601
(
Suprenant
1986a)/
Acceptable
Estuarine/
Marine
Invertebrates
Quahog
clam
(
Mercenaria
mercenaria)
TCMTB
80%
48­
hr.
static
EC50
=
13.9
ug/
L
(
ppb);
NOEC
<
13
ug/
L
(
ppb)
Very
highly
toxic
40363603
(
Suprenant
1986)
/
Acceptable
Mysid
(
Americamysis
bahia,
formerly
Mysidopsis
bahia)
TCMTB
80%
96­
hour
static
LC50=
20.3
ug/
L
(
ppb);
NOEC
<
7.8
ug/
L
(
ppb)
Very
highly
toxic
40363602
(
Suprenant
1987)
/
Acceptable
43
Table
21.
Avian
Sub­
acute
Dietary
Toxicity
of
TCMTB
and
2­
MBT
Test
Type
(
Chemical
and
%
a.
i.)
Chemical
(%
a.
i.)
Species
Endpoint
Results
Other
Effects
Noted
Reference/
Status
TCMTB
(
80­
83%
a.
i.)
Mallard
duck
(
Anas
platyrhynchos)
Mortality
8­
day
LC50
>
10000
ppm
"
practically
non­
toxic"
Feed
consumption
and
10%
mortality
at
5,000
and
10,000
ppm
Accession
#
009869
(
Booden,
1974)/
Acceptable
TCMTB
(
75
%
a.
i.)
Bobwhite
quail
(
Colinus
virginianus)
Mortality
LC50
>
10000
ppm
"
Practically
non­
toxic"
Huddling
and
depression
at
levels
>
1000
ppm
Accession
#
091624
(
Knott
and
Woodard,
1968a)/
Supplemental
TCMTB
(
80%
a.
i.)
Mallard
duck
(
Anas
platyrhynchos)
Mortality
8­
day
LC50
>
4496
ppm
"
Slightly
toxic"
NOEC
<
450
ppm
based
on
reduction
in
body
weight
gain
and
food
consumption
415956­
01
(
Long
et
al.,
1990/
Acceptable
TCMTB
(
80%
a.
i.)
Bobwhite
quail
(
Colinus
virginianus)
Mortality
8­
day
LC50
>
4496
ppm
"
Slightly
toxic"
NOEC
=
450
ppm,
based
on
reduction
of
average
body
weight
gain
at
higher
levels
415956­
02
(
Long
et
al.,
1990/
Acceptable
Avian
acute
dietary,
850.2200/
71­
2
2­
MBT
(
98.22%
a.
i.)
Bobwhite
quail
(
Colinus
virginianus
Mortality
8­
day
LC50
>
3387
ppm
"
Slightly
toxic"
NOEC
=
3387
ppm
 
no
signs
of
toxicity
at
any
level
424285­
01(
Pedersen
and
Helsten,
1992b)/
Acceptable
Table
22.
Freshwater
Fish
Chronic
Toxicity
of
TCMTB
Study
Type
Species
Endpoint
NOEC

g
a.
i./
l
LOEC

g
a.
i./
l
MRID#
(
reference)/
Status
Freshwater
fish
Early
life­
stage
toxicity
(
72­
4a/
850.1300)
(
83.78%
a.
i.)
Rainbow
trout
(
Oncorhynchus
mykiss)
Reproduction,
post­
hatch
survival,
growth
0.34
ppb
based
on
growth
and
egg
hatchability
0.56
ppb
based
on
growth
425959­
01
(
Rhodes,
1992)/
Acceptable
44
Table
23.
TCMTB
Aquatic
Plant
Toxicity
Test
Species/%
a.
i.
Endpoint
Toxicity
NOEC/
other
effects
noted
MRID
(
reference)
Status
Aquatic
Vascular
Plant
Acute
Toxicity,
Tier
II
(
doseresponse
123­
2/
850.4400
Duckweed
(
Lemna
gibba)/
83.5%
a.
i.
Frond
growth
14­
day
static
renewal
EC50
=
0.43
(
0.29
 
0.65)
mg/
L
(
ppm)
0.15
mg/
L
(
ppm)
442009­
01
(
Thompson
and
Swigert,
1996)
Acceptable
b.
Ecological
Exposure
and
Risk
The
Agency
has
evaluated
the
outdoor
uses
of
TCMTB
being
considered
for
reregistration.
Environmental
exposure
modeling
was
conducted
for
both
the
agricultural
and
antimicrobial
uses
of
TCMTB.

Terrestrial
Organisms
Modeling
was
performed
to
address
the
exposure
and
risk
to
birds
and
mammals
consuming
seeds
treated
with
TCMTB
using
the
Terrestrial
Residue
Exposure
Model
(
TREX)
(
http://
www.
epa.
gov/
oppefed1/
models/
terrestrial)
for
the
treatment
on
safflower,
which
has
the
highest
application
rate
of
0.041
lb
ai/
A.
The
Agency
determined
that
acute
risk
to
birds
and
mammals
from
consuming
TCMTB­
treated
seeds
are
below
the
Agency's
level
of
concern
(
LOC).
The
following
Risk
Quotients
(
RQs)
for
acute
and
chronic
avian
exposure
to
TCMTB
treated
seeds
were
calculated:

Avian
Acute:
0.02
as
(
mg
ai/
kg/
day)/
LD50
Avian
Chronic:
Not
required
The
avian
RQ
was
calculated
with
no
toxicity
scaling
factor.
Scaling
factors
are
used
when
it
is
likely
that
a
pesticide
will
be
proportionally
more
toxic
to
smaller
organisms
than
larger
ones.
TREX
recommended
a
default
scaling
factor
of
1.15,
based
on
Mineaue
et
al.
(
1996).
This
scaling
factor
was
developed
based
on
37
conventional
pesticides,
most
of
which
are
cholinesterase
inhibitors.
There
is
no
information
available
indicating
that
such
an
adjustment
is
necessary
or
appropriate
for
TCMTB.
The
following
Risk
Quotients
(
RQs)
for
acute
and
chronic
mammalian
exposure
to
TCMTB
treated
seeds
were
calculated:

Mammalian
Acute:
0.05
as
(
mg
ai/
kg/
day)/
LD50,
0.02
as
(
mg
ai/
ft2)/(
LD50*
BW)
Mammalian
Chronic:
0.53
as
(
mg/
kg
seed)/
reproduction
NOAEC
All
of
the
agricultural
use
RQs
are
below
any
LOCs
for
avian
and
mammalian
acute
risk
and
mammalian
chronic
risk.
Avian
chronic
data
are
not
available
or
required
for
the
currently
registered
uses
of
TCMTB,
therefore
chronic
avian
risk
was
not
assessed.

Terrestrial
risks
from
the
wood
preservative
uses
of
TCMTB
were
not
addressed
due
to
a
lack
of
available
models
to
estimate
terrestrial
exposure
from
antisapstain
treatments.
The
45
Agency
conducted
environmental
exposure
modeling
for
the
antisapstain
wood
preservation
use.
Runoff
concentrations
of
TCMTB
were
estimated
for
facilities
that
treat
wood
with
antisapstain
chemicals.
The
concentrations
were
estimated
using
an
approach
developed
to
determine
runoff
concentrations
of
pesticides
from
antisapstain
facilities
in
British
Columbia,
Canada
(
Krahn
and
Strub,
1990).

Predictions
of
leaching
behavior
(
as
would
be
observed
in
a
study
following
the
Krahn
and
Strub
(
1990)
protocol)
were
made
based
on
the
chemical
properties
of
TCMTB
and
a
number
of
assumptions.

Krahn
and
Strub
(
1990)
assume
that
leachate
entering
the
storm
drain
is
diluted
with
extra
runoff
water
at
a
1:
15
ratio.
This
is
based
on
measurements
of
runoff
in
storm
drains
at
facilities
using
antisapstain
chemicals
in
British
Columbia.
Use
of
the
ratios
1:
6
and
1:
23
were
also
suggested
by
Krahn
and
Strub
(
1990)
to
determine
a
"
general
industry
wide"
predicted
runoff
concentration.
These
values
were
used
in
this
assessment.
The
estimated
leachate
concentration
(
0.196
ppm)
was
used
in
conjunction
with
these
dilution
factors
to
estimate
runoff
concentrations.

Table
24.
Estimated
Runoff
Concentrations
for
TCMTB
from
Antisapstain
Use
Parameter
Dilution
Factor
Estimated
Runoff
Concentration
(
ppm)
a
High­
end
dilution
23.0
0.00852
Typical
dilution
15.0
0.0131
Low­
end
dilution
6.00
0.0327
aEstimated
Runoff
Concentration
=
Estimated
Leachate
Concentration
(
0.196
ppm)
/
Dilution
Factor.

Aquatic
Organisms
To
develop
risk
quotients
(
RQs),
the
estimated
environmental
concentrations
(
EECs)
determined
by
modeling
were
compared
to
the
most
sensitive
endpoint
for
each
taxa.
For
seed
treatment,
no
levels
of
concern
(
LOCs)
were
exceeded.
The
seed
treatment
use
of
TCMTB
poses
minimal
risk
to
aquatic
organisms
and,
therefore,
is
below
the
Agency's
level
of
concern.

The
Agency
has
also
conducted
environmental
exposure
modeling
for
the
antisapstain
wood
preservative
use.
Based
on
the
Tier
I
screening
model
used
for
the
antisapstain
use,
there
are
risks
of
concern
to
aquatic
organisms.
Acute
LOCs
were
exceeded
for
all
taxa
except
aquatic
plants.
Chronic
LOCs
for
fish
were
also
exceeded.
However,
chronic
risk
to
invertebrates
could
not
be
addressed
due
to
lack
of
chronic
invertebrate
toxicity
data.
Additional
information
regarding
the
TCMTB
ecological
assessment
can
be
found
in
the
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,"
dated
August
1,
2006;
and
the
"
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Ecological
Hazard
and
Environmental
Risk
Assessment
Chapter­
Revised,"
dated
August
1,
2006.
Please
refer
to
Table
25
for
a
comprehensive
list
of
the
identified
aquatic
organism
risk
quotients
for
the
seed
treatment
and
antimicrobial
uses
of
TCMTB.
46
Table
25.
Aquatic
Organism
Risk
Quotients
for
Seed
Treatment
and
Antisapstain
Uses
of
TCMTB
Taxa/
Endpoint
Seed
treatment
EEC
Seed
Treatment
RQ
Antisapstain
EEC
Low
dilution
High
dilution
Antisapstain
RQ
Freshwater
fish
Acute
8.7
µ
g/
L
0.28
ppb
0.03
32.7
ppb
8.5
ppb
3.76
0.98
Freshwater
Invertebrates
Acute
22
µ
g/
L
0.28
ppb
0.01
32.7
ppb
8.5
ppb
1.49
0.39
Marine/
Estuarine
Fish
Acute
60
µ
g/
L
0.28
ppb
0.00
32.7
ppb
8.5
ppb
0.54
0.14
Marine/
Estuarine
Bivalve
Acute
13.9
µ
g/
L
0.28
ppb
0.02
32.7
ppb
8.5
ppb
2.35
0.61
Marine/
Estuarine
Invertebrate
Acute
20.3
µ
g/
L
0.28
ppb
0.01
32.7
ppb
8.5
ppb
1.61
0.42
Green
Algae
Acute
EC50
430
µ
g/
L
0.28
ppb
0.00
32.7
ppb
8.5
ppb
0.08
0.02
Green
Algae
NOEC
150
µ
g/
L
0.28
ppb
0.00
32.7
ppb
8.5
ppb
0.22
0.06
Fish
Chronic
0.34
µ
g/
L
0.12
ppb
0.35
13.1
ppb
8.5
ppb
38.53
25.00
Invertebrate
Chronic
 
DATA
GAP
0.20
ppb
­­­­­
13.1
ppb
­­­­­

Plants
A
single
aquatic
plant
study
was
submitted
for
TCMTB,
the
results
of
which
are
summarized
in
Table
23.
Results
indicate
that
TCMTB
exposure
impairs
growth
of
aquatic
vascular
plants
at
levels
greater
than
0.15
ppm
(
150
ppb).
Further
data
are
required
to
support
the
antimicrobial
and
agricultural
uses
of
TCMTB.

Non­
target
Insects
(
Honeybee)

Honeybees
could
potentially
be
exposed
to
pesticide
residues
if
treated
wood
is
used
to
construct
hives
or
hive
components.
These
residues
may
be
toxic
to
the
bees
or
result
in
residues
in
honey
or
other
hive
products
intended
for
human
use/
consumption.
Therefore,
a
special
honeybee
study
is
required
for
all
wood
preservative
uses
unless
a
statement
prohibiting
the
use
of
treated
wood
in
hive
construction
is
added
to
the
label
such
as,
"
Wood
treated
with
TCMTB
shall
not
be
used
in
the
construction
of
beehives."
This
study
is
a
combination
of
Guidelines
171­
4
and
850.3030
(
see
information
regarding
residue
data
requirements
for
uses
in
beehives
in
the
residue
chemistry
section
of
40
CFR
part
158).
Numbers
of
bees
used
in
this
study
and
methods
for
collection/
introduction
of
bees
into
hives,
feeding,
and
observations
for
toxicity
and
mortality
should
be
consistent
with
those
described
in
OPPTS
Guideline
850.3030,
"
Honey
Bee
Toxicity
of
Residues
on
Foliage."
The
toxicity
portion
of
this
study
is
in
lieu
of
the
honeybee
contact
LD50
test.
47
c.
Risk
to
Listed
Species
Section
7
of
the
Endangered
Species
Act,
16
U.
S.
C.
Section
1536(
a)(
2),
requires
all
federal
agencies
to
consult
with
the
National
Marine
Fisheries
Service
(
NMFS)
for
marine
and
anadromous
listed
species,
or
the
United
States
Fish
and
Wildlife
Services
(
FWS)
for
listed
wildlife
and
freshwater
organisms,
if
they
are
proposing
an
"
action"
that
may
affect
listed
species
or
their
designated
habitat.
Each
federal
agency
is
required
under
the
Act
to
insure
that
any
action
they
authorize,
fund,
or
carry
out
is
not
likely
to
jeopardize
the
continued
existence
of
a
listed
species
or
result
in
the
destruction
or
adverse
modification
of
designated
critical
habitat.
To
jeopardize
the
continued
existence
of
a
listed
species
means
"
to
engage
in
an
action
that
reasonably
would
be
expected,
directly
or
indirectly,
to
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
the
species"
(
50
C.
F.
R.
'
402.02).

To
facilitate
compliance
with
the
requirements
of
the
Endangered
Species
Act
subsection
(
a)(
2)
the
Environmental
Protection
Agency,
Office
of
Pesticide
Programs
has
established
procedures
to
evaluate
whether
a
proposed
registration
action
may
directly
or
indirectly
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
any
listed
species
(
U.
S.
EPA
2004).
After
the
Agency's
screening­
level
risk
assessment
is
performed,
if
any
of
the
Agency's
Listed
Species
LOC
Criteria
are
exceeded
for
either
direct
or
indirect
effects,
a
determination
is
made
to
identify
if
any
listed
or
candidate
species
may
co­
occur
in
the
area
of
the
proposed
pesticide
use.
If
determined
that
listed
or
candidate
species
may
be
present
in
the
proposed
use
areas,
further
biological
assessment
is
undertaken.
The
extent
to
which
listed
species
may
be
at
risk
then
determines
the
need
for
the
development
of
a
more
comprehensive
consultation
package
as
required
by
the
Endangered
Species
Act.

For
certain
use
categories,
the
Agency
assumes
there
will
be
minimal
environmental
exposure,
and
only
a
minimal
toxicity
data
set
is
required
(
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
1/
23/
04,
Appendix
A,
Section
IIB,
pg.
81).
Chemicals
in
these
categories
therefore
do
not
undergo
a
full
screening­
level
risk
assessment,
and
are
considered
to
fall
under
a
no
effect
determination.
The
active
ingredient
uses
of
TCMTB,
with
the
exception
of
the
seed
treatment
and
antisapstain
wood
preservation
uses,
fall
into
this
category.
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
seed
treatment
risks
to
Listed
Species
were
not
identified.
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
antisapstain
wood
preservation
uses
of
TCMTB,
risks
to
Listed
Species
are
indicated.
Since
the
model
is
only
intended
as
a
screening­
level
model,
and,
as
such,
has
inherent
uncertainties
and
limitations
which
may
result
in
inaccurate
exposure
estimations,
further
refinement
of
the
model
is
recommended
before
any
regulatory
action
is
taken
regarding
the
antisapstain
uses
of
TCMTB.
Additionally,
impacts
from
the
antisapstain
use
could
potentially
be
mitigated
with
precautions
to
prevent
leaching
and
runoff
when
wood
is
stored
outdoors
(
see
General
Risk
Mitigation,
below).
Due
to
these
circumstances,
the
Agency
defers
making
a
determination
for
the
antisapstain
uses
of
TCMTB
until
additional
data
and
modeling
48
refinements
are
available.
At
that
time,
the
environmental
exposure
assessment
of
the
antisapstain
use
of
TCMTB
will
be
revised,
and
the
risks
to
Listed
Species
will
be
reconsidered.
49
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
TCMTB
as
an
active
ingredient.
The
Agency
has
completed
its
review
of
these
generic
data
and
has
determined
that
the
data
are
sufficient
to
support
reregistration
of
all
supported
products
containing
TCMTB.

The
Agency
has
completed
its
assessment
of
the
dietary,
occupational,
drinking
water,
and
ecological
risks
associated
with
the
use
of
pesticide
products
containing
the
active
ingredient
TCMTB.
Based
on
a
review
of
these
data
and
on
public
comments
on
the
Agency's
assessments
for
the
active
ingredient
TCMTB,
the
Agency
has
sufficient
information
on
the
human
health
and
ecological
effects
of
TCMTB
to
make
decisions
as
part
of
the
tolerance
reassessment
process
under
FFDCA
and
reregistration
process
under
FIFRA,
as
amended
by
FQPA.
The
Agency
has
determined
that
TCMTB­
containing
products
are
eligible
for
reregistration
provided
that:
(
i)
current
data
gaps
and
confirmatory
data
needs
are
addressed;
(
ii)
the
risk
mitigation
measure
outlined
in
this
document
is
adopted;
and
(
iii)
label
amendments
are
made
to
reflect
this
measure.
Label
changes
are
described
in
Section
V.
Appendix
A
summarizes
the
uses
of
TCMTB
that
are
eligible
for
reregistration.
Appendix
B
identifies
the
generic
data
requirements
that
the
Agency
reviewed
as
part
of
its
determination
of
reregistration
eligibility
of
TCMTB
and
lists
the
submitted
studies
that
the
Agency
found
acceptable.
Data
gaps
are
identified
as
generic
data
requirements
that
have
not
been
satisfied
with
acceptable
data.

Based
on
its
evaluation
of
TCMTB,
the
Agency
has
determined
that
TCMTB
products,
unless
labeled
and
used
as
specified
in
this
document,
would
present
risks
inconsistent
with
FIFRA.
Accordingly,
should
a
registrant
fail
to
implement
the
risk
mitigation
measure
identified
in
this
document,
the
Agency
may
take
regulatory
action
to
address
the
risk
concerns
from
the
use
of
TCMTB.
If
all
changes
outlined
in
this
document
are
incorporated
into
the
product
labels,
then
all
current
risks
for
TCMTB
will
be
substantially
mitigated
for
the
purposes
of
this
determination.
Once
an
Endangered
Species
assessment
is
completed,
further
changes
to
these
registrations
may
be
necessary
as
explained
in
Section
III
of
this
document.

B.
Public
Comments
and
Responses
Through
the
Agency's
public
participation
process,
the
EPA
worked
with
stakeholders
and
the
public
to
reach
the
regulatory
decision
for
TCMTB.
EPA
released
its
preliminary
risk
assessment
for
TCMTB
for
public
comment
on
April
26,
2006.
The
Agency
received
no
comments
during
the
60­
day
public
comment
period
on
the
TCMTB
risk
assessment
and
supporting
science
documents,
which
closed
on
June
26,
2006.
50
C.
Regulatory
Position
1.
Food
Quality
Protection
Act
Findings
a.
"
Risk
Cup"
Determination
As
part
of
the
FQPA
tolerance
reassessment
process,
EPA
assessed
the
risks
associated
with
TCMTB
use.
The
Agency
has
determined
that,
if
the
mitigation
described
in
this
document
is
adopted
and
labels
are
amended,
human
health
risks
as
a
result
of
exposures
to
TCMTB
are
within
acceptable
levels.
In
other
words,
EPA
has
concluded
that
the
tolerances
for
TCMTB
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
exposures
to
TCMTB
from
all
possible
sources.

b.
Determination
of
Safety
to
U.
S.
Population
As
part
of
the
FQPA
tolerance
reassessment
process,
EPA
assessed
the
risks
associated
with
TCMTB.
The
Agency
has
determined
that
the
tolerances
for
TCMTB,
with
amendments
and
changes
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
TCMTB.
In
reaching
this
conclusion,
the
Agency
has
considered
all
available
information
on
the
toxicity,
use
practices
and
exposure
scenarios,
and
the
environmental
behavior
of
TCMTB.

Dietary
risk
assessments
were
conducted
for
adults
and
children,
with
the
highest
risks
(
children
at
2%
aPAD
for
seed
treatment
use
and
children
at
0.66%
aPAD
for
antimicrobial
use;
children
at
17%
of
cPAD
for
seed
treatment
use
and
children
at
12.8%
cPAD)
being
below
the
Agency's
level
of
concern.

The
Agency
conducted
acute
and
chronic
aggregate
assessments
that
considered
food
and
drinking
water
exposures
from
the
registered
agricultural
and
antimicrobial
uses
of
TCMTB.
The
residential
uses
of
TCMTB
were
not
included
in
the
aggregate
assessment
because
all
of
the
residential
uses
evaluated
have
risks
of
concern
(
MOEs
<
100).
Thus,
the
short­
and
intermediate­
term
aggregate
assessment
that
included
the
residential
uses
would
also
show
risks
of
concern.

The
subpopulation
with
the
greatest
risk
for
both
the
acute
and
chronic
aggregate
risk
assessments
was
children
(
2.5%
of
aPAD
for
children
and
40%
of
cPAD
for
children).
These
risk
estimates
are
below
the
Agency's
level
of
concern.

c.
Determination
of
Safety
to
Infants
and
Children
EPA
has
determined
that
the
currently
registered
uses
of
TCMTB,
with
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
factors
of
the
toxicity,
use
51
practices,
and
environmental
behavior
noted
above
for
the
general
population,
but
also
takes
into
account
the
possibility
of
increased
susceptibility
to
the
toxic
effects
of
TCMTB
residues
in
this
population
subgroup.

No
Special
FQPA
Safety
Factor
is
necessary
to
protect
the
safety
of
infants
and
children.
In
determining
whether
or
not
infants
and
children
are
particularly
susceptible
to
toxic
effects
from
TCMTB
residues,
the
Agency
considered
the
completeness
of
the
database
for
developmental
and
reproductive
effects,
the
nature
of
the
effects
observed,
and
other
information.
The
FQPA
Safety
Factor
has
been
removed
(
i.
e.,
reduced
to
1X)
for
TCMTB
based
on:
(
1)
the
toxicology
database
is
complete
with
respect
to
assessing
the
increased
susceptibility
to
infants
and
children
as
required
by
FQPA;
(
2)
there
is
no
concern
for
developmental
neurotoxicity
resulting
from
exposure
to
TCMTB
in
the
rat
and
rabbit
prenatal
developmental
studies
and
the
2­
generation
reproduction
study;
(
3)
there
is
no
evidence
of
increased
susceptibility
to
the
fetus
following
in
utero
exposure
in
the
prenatal
developmental
toxicity
studies
or
to
the
offspring
when
adults
are
exposed
in
the
two­
generation
reproductive
study;
and
(
4)
the
risk
assessment
does
not
underestimate
the
potential
exposure
for
infants
and
children.

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."
Following
recommendations
of
its
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee
(
EDSTAC),
EPA
determined
that
there
was
a
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
EPA
include
evaluations
of
potential
effects
in
wildlife.
For
pesticides,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).

In
the
chronic
rat
toxicity/
carcinogenicity
study,
TCMTB
was
associated
with
thyroid
Ccell
adenomas.
Although
these
results
were
not
seen
as
statistically
significant,
they
may
indicate
an
association
with
endocrine
disruption.
When
the
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
EDSP
have
been
developed,
TCMTB
may
be
subject
to
additional
screening
and/
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

e.
Cumulative
Risks
Risks
summarized
in
this
document
are
those
that
result
only
from
the
use
of
TCMTB.
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
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
as
would
a
higher
level
of
exposure
to
any
of
the
substances
individually.
Unlike
52
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
TCMTB.
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/.

2.
Tolerance
Summary
Tolerances
for
residues
in/
on
plant
livestock
commodities
have
been
established
under
40
CFR
§
180.288.
The
permanent
tolerances
for
residues
in/
on
plant
commodities
are
established
at
the
limit
of
quantitation
(
LOQ)
of
0.1
ppm
(
N)
and
are
expressed
in
term
of
residues
of
TCMTB
per
se
[(
2­
benzothiazolylthio)
methyl
thiocyanate].

Confirmatory
metabolism
data
conducted
with
wheat,
cotton,
and
sugar
beet
are
necessary
to
determine
the
nature
of
residues
in
plants.
Depending
on
the
results
from
the
confirmatory
metabolism
studies,
additional
guideline
requirements
may
be
requested
for:
livestock
metabolism;
storage
stability;
and
magnitude
of
the
residue
studies
on
livestock,
processed
crop
commodities,
and
magnitude
of
residue
studies
for
rotational
crops.
A
summary
of
the
TCMTB
tolerance
reassessment
is
presented
below
in
Table
26.

a.
Currently
Established
Tolerances
Under
40
CFR
180.288
&
Tolerance
Reassessment
of
TCMTB
Tolerances
for
barley
hay
and
cotton
gin
byproducts
must
be
proposed.
The
"
N"
designation,
denoting
"
negligible"
residues,
must
be
deleted
from
40
CFR
§
180.288.
Use
of
TCMTB
on
sorghum
and
corn
are
no
longer
supported
and,
therefore,
must
be
revoked
under
40
CFR
§
180.288.
53
Table
26.
Established
Tolerances
and
Tolerance
Reassessment
Summary
Table
for
TCMTB
Commodity
Current
Tolerance
Tolerance
Reassessment
Comment/[
Correct
Commodity
Definition]
Tolerances
Established
Under
40
CFR
§
180.288:
Barley,
grain
0.1
(
N1)
TBD2
Barley,
straw
0.1
(
N)
TBD
Beet,
sugar,
roots
0.1
(
N)
TBD
Beet,
sugar,
tops
0.1
(
N)
TBD
Corn,
grain
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Corn,
forage
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Corn,
stover
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Cotton,
forage
0.1
(
N)
Revoke
No
longer
considered
a
significant
livestock
feed
item.
Cotton,
undelinted
seed
0.1
(
N)
TBD
Oat,
forage
0.1
(
N)
TBD
Oat,
grain
0.1
(
N)
TBD
Oat,
hay
0.1
(
N)
TBD
Oat,
straw
0.1
(
N)
TBD
Rice,
grain
0.1
(
N)
TBD
Rice,
straw
0.1(
N)
TBD
Safflower,
seed
0.1
(
N)
TBD
Sorghum,
grain,
forage
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.

Sorghum,
grain,
grain
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.

Sorghum,
grain,
stover
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.
Wheat,
forage
0.1
(
N)
TBD
Wheat,
grain
0.1
(
N)
TBD
Wheat,
hay
0.1
(
N)
TBD
Wheat,
straw
0.1
(
N)
TBD
Tolerances
To
Be
Proposed
Under
40
CFR
§
180.288:
Barley,
hay
None
established
TBD
Cotton,
gin
byproducts
None
established
TBD
1.
N
=
Negligible.
The
"
N"
designation
must
be
removed
from
all
tolerances.
2.
TBD
=
To
be
determined.
Tolerances
cannot
be
determined
at
this
time
because
additional
data
are
required.

b.
Codex
of
Harmonization
There
are
no
codex
maximum
residue
limits
(
MRLs)
for
TCMTB;
therefore,
no
questions
of
compatibility
with
U.
S.
tolerances
exist.

D.
Regulatory
Rationale
The
Agency
has
determined
that
TCMTB
is
eligible
for
reregistration
provided
that
additional
required
data
confirm
this
decision,
the
risk
mitigation
measures
outlined
in
this
document
are
adopted,
and
label
amendments
are
made
to
reflect
these
measures.
54
The
following
is
a
summary
of
the
rationale
for
managing
risks
associated
with
the
uses
of
TCMTB.
Where
labeling
revisions
are
warranted,
specific
language
is
set
forth
in
the
summary
tables
of
Section
V
of
this
document.

1.
Human
Health
Risk
Management
a.
Dietary
(
Food)
Risk
Mitigation
The
acute
and
chronic
dietary
risks
from
TCMTB
residues
on
food,
estimated
using
conservative
measures
are
below
the
Agency's
level
of
concern
for
the
seed
treatment
and
antimicrobial
uses.
Therefore,
no
mitigation
measures
are
necessary
at
this
time.
Additional
confirmatory
metabolism
data
are
required
to
verify
that
2­
MBT
and
other
TCMTB
metabolites
are
not
residues
of
concern
in
plant
commodities.

b.
Drinking
Water
Risk
Mitigation
The
Agency
estimated
drinking
water
exposure
for
the
seed
treatment
use
of
TCMTB
only,
as
no
antimicrobial
uses
are
expected
to
impact
surface
or
groundwater
resources.
The
drinking
water
concentrations
did
not
result
in
risk
of
concern.
Therefore,
no
mitigation
measures
are
necessary
at
this
time.

c.
Residential
Risk
Mitigation
i.
Handler
Risk
Mitigation
Residential
handler
risks
were
assessed
for
the
application
of
TCMTB­
preserved
paint
via
airless
sprayer
and
paint
brush/
roller
(
antimicrobial
uses)
to
determine
dermal
and
inhalation
exposure.
Short­
term
dermal
risks
of
concern
were
identified
for
paint
applicators
using
both
airless
sprayer
and
paint
brush/
roller
scenarios
(
ST
Dermal
MOE
of
10
for
airless
sprayer
applications
and
ST
Dermal
MOE
of
25
for
paintbrush
applications).
The
inhalation
MOEs
were
above
the
target
MOE
of
300;
however,
the
total
dermal
and
inhalation
MOEs
for
both
application
scenarios
were
under
the
target
MOE
of
100
and,
thus,
are
risks
of
concern.

Because
of
remaining
residential
exposure
concerns,
the
registrants
for
TCMTB
have
agreed
to
conduct
a
dermal
exposure
study
for
paint
applicators
that
would
allow
the
Agency
to
assess
the
risks
associated
with
these
uses.
However,
this
study
will
not
be
completed
in
time
for
inclusion
in
this
RED.
Until
acceptable
exposure
data
are
submitted,
the
Agency
has
determined
that
the
residential
use
of
TCMTB
as
a
materials
preservative
in
paints
is
ineligible
for
reregistration
and
this
use
must
be
deleted.
The
registrant
has
agreed
that
once
the
data
has
been
determined
to
be
acceptable,
and
if
it
is
established
that
the
risks
are
not
of
concern,
the
registrants
can
request
that
this
use
be
reinstated.

ii.
Post­
Application
Risk
Mitigation
For
the
residential
post­
application
assessment,
high­
end
residential
exposures
were
assessed
for
treated
carpets
(
dermal
and
incidental
oral
exposure
to
children)
and
treated
55
clothing/
leather
products
(
dermal
exposure
to
adults/
children
and
incidental
oral
exposure
to
children).
The
short­
and
intermediate­
term
MOEs
for
dermal
contact
with
treated
clothing/
leather
products
were
of
concern
for
both
young
children
and
adults
(
MOEs
<
1
assuming
100%
transfer
factor;
MOEs
<
10
assuming
5%
transfer
factor).
In
addition,
the
shortterm
MOEs
for
dermal
and
incidental
oral
contact
with
treated
carpet
were
less
then
the
target
of
100
for
children
(
ST
dermal
MOE
of
2,
ST
oral
MOE
of
4).

To
address
these
risks
all
TCMTB
textile
preservative
uses,
with
the
exception
of
the
leather
preservative
use,
must
be
deleted.
In
addition,
the
registrant
has
agreed
to
conduct
a
study
on
TCMTB­
treated
leather
products
to
determine
how
much
TCMTB
would
transfer
onto
skin
through
normal
wear.
This
study,
which
is
confirmatory
data,
is
expected
to
further
refine
the
risk
assessment
for
the
leather
preservative
use.

As
a
result
of
the
cancellation
of
the
textile
use,
the
Agency
has
determined
that
all
dermal
and
oral
risks
of
concern
pertaining
to
children
will
be
eliminated.
The
rationale
for
this
decision
is
that
children
are
not
likely
to
come
into
oral
contact
through
mouthing
of
treated
leather
products.
In
addition,
children
are
not
likely
to
wear
TCMTB­
treated
leather
products.
Therefore,
there
are
no
remaining
risks
of
concern
for
residential
exposure
of
TCMTB­
treated
leather
products
to
children.

Preliminary
data
was
submitted
by
the
technical
registrant,
Buckman
Laboratories,
to
the
Agency
regarding
leaching
of
TCMTB
from
treated
leather.
This
data
estimated
the
amount
of
TCMTB
that
would
transfer
to
the
skin
during
normal
wear
of
leather
products.
A
preliminary
review
of
this
data
was
used
to
characterize
risks
associated
with
wearing
treated
leather
and
suggests
that
dermal
risks
from
wearing
these
products
well
exceeds
the
target
MOE
of
100
for
adults
and,
thus,
is
not
of
concern.
Confirmatory
leather
leaching
data
is
required
to
support
these
findings.

d.
Occupational
Risk
Mitigation
i.
Handler
Risk
Mitigation
Seed
Treatment
Use
For
commercial
seed
treatment,
all
dermal
and
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
with
baseline
levels
of
PPE.
Therefore,
no
mitigation
is
required.

Antimicrobial
Use
Dermal
risks
of
concern
were
identified
for
six
individual
use
scenarios
(
paint
preservation
liquid
pour,
paint
preservation
liquid
pump,
textile
preservation
liquid
pour,
textile
preservation
liquid
pump,
cutting
fluid
preservation
liquid
pour,
pulp
and
paper
liquid
pump)
at
the
baseline
level
of
evaluation
(
no
PPE
gloves).
To
mitigate
the
risks
for
occupational
handlers
of
material
preservation
for
adhesives,
pulp
and
paper
and
metalworking,
these
workers
must
wear
chemical
resistant
gloves
while
handling
TCMTB
products.
The
use
of
chemical
resistant
56
gloves
eliminates
the
dermal
risks
of
concern
(
MOEs
are
well
above
100
with
the
addition
of
gloves).
Paint
and
textile
uses,
with
the
exception
of
leather,
must
be
deleted
based
on
residential
risk
concerns.

Short­
term
and
intermediate­
term
dermal
risks
of
concern
were
identified
for
occupational
paint
applicators
with
the
use
of
an
airless
sprayer
and
paintbrush/
roller.
These
risks
remained
a
concern,
even
with
addition
of
PPE
(
gloves).
Because
of
remaining
risk
concerns
associated
with
this
use,
the
technical
registrant
for
TCMTB
has
agreed
to
conduct
a
study
that
would
allow
the
Agency
to
assess
the
risks
associated
with
these
uses.
However,
this
study
will
not
be
completed
in
time
for
inclusion
in
this
RED.
Until
acceptable
exposure
data
are
submitted,
the
Agency
has
determined
that
the
occupational
use
of
TCMTB
in
commercial
and
institutional
premises
for
paint
application
is
ineligible
for
reregistration
and
paint
uses
must
be
deleted.
Once
the
data
has
been
determined
to
be
acceptable,
and
if
it
is
established
that
the
risks
are
not
of
concern,
the
registrants
can
request
that
this
use
be
reinstated.

Dermal
risks
of
concern
were
identified
for
occupational
handlers
of
textiles
and
carpets
being
treated
with
TCMTB.
To
mitigate
these
risks
all
textile
uses
of
TCMTB
must
be
deleted,
with
the
exception
of
leather.
To
mitigate
the
dermal
risks
for
handlers
during
the
manufacturing
of
leather
products,
pulp
and
paper
products,
and
handling
of
metal
cutting
fluid,
workers
must
wear
gloves.
The
estimates
for
these
risks
are
well
over
the
target
of
100
and
are
not
of
concern
with
the
use
of
gloves.

The
short­,
intermediate­
and
long­
term
risks
for
occupational
handlers
who
apply
TCMTB
to
wood
for
non­
pressure
treatment
were
assessed.
All
of
these
risks
were
above
the
target
MOEs
of
100
(
short­
and
intermediate­
term)
and
300
(
long­
term),
and
are
not
of
concern.

ii.
Post­
Application
Risk
Mitigation
For
the
occupational
post­
application
risk
assessment
of
the
seed
treatment
and
antimicrobial
uses
of
TCMTB,
there
are
no
risks
of
concern.
Therefore,
mitigation
measures
are
not
necessary
at
this
time.

2.
Environmental
Risk
Management
Seed
Treatment
Use
The
Agency
considers
the
seed
treatment
use
of
TCMTB
assessed
in
this
RED
to
be
unlikely
to
result
in
any
appreciable
exposure
to
terrestrial
or
aquatic
organisms.
Therefore
no
environmental
risk
mitigation
is
required
for
the
agricultural
use
of
TCMTB
at
this
time.

Antimicrobial
Use
For
the
antisapstain
use
of
TCMTB,
the
Agency
used
a
Tier
I
screening
model
to
estimate
exposures
that
could
result
from
this
use.
The
worst
case
ecological
concern
for
the
TCMTB
antisapstain
use
is
for
chronic
risk
to
fish
with
RQs
ranging
from
25
 
39.
The
estimated
environmental
concentrations
(
EECs)
exceed
chronic
levels
of
concern
(
LOCs).
It
should
be
noted
that
this
model
has
inherent
assumptions
and
uncertainties
that
may
result
in
over
or
under
estimation
of
exposure
levels.
Additional
information,
including,
specific
leaching
57
data
from
TCMTB
used
as
an
antisapstain
wood
preservative
would
result
in
more
accurate
risk
estimations.
Therefore,
the
Agency
is
requesting
an
aerobic
soil
metabolism,
anaerobic
soil
metabolism,
and
aerobic
aquatic
metabolism
studies.
Such
data
may
remove
uncertainties
and
may
result
in
more
accurate
exposure
estimations
In
addition,
the
following
language
must
be
placed
on
all
antisapstain
products
to
decrease
leaching
risks:

"
Treated
lumber
must
be
stored
under
cover,
indoors,
or
at
least
100
feet
from
any
pond,
lake,
stream,
wetland,
or
river
to
prevent
possible
runoff
of
the
product
into
the
waterway.
Treated
lumber
stored
within
100
feet
of
a
pond,
lake,
steam,
or
river
must
be
either
covered
with
plastic
or
surrounded
by
a
berm
to
prevent
surface
water
runoff
into
the
nearby
waterway.
If
a
berm
or
curb
is
used
around
the
site,
it
should
consist
of
impermeable
material
(
clay,
asphalt,
concrete)
and
be
of
sufficient
height
to
prevent
runoff
during
heavy
rainfall
events."

Registrants
are
responsible
for
amending
all
TCMTB
wood
preservative
product
labels
to
incorporate
the
required
label
language,
which
will
help
mitigate
ecological
risks
of
concern.

To
address
exposure
to
non­
target
insects,
a
special
honeybee
study
is
required
for
all
wood
preservative
uses
unless
a
statement
prohibiting
the
use
of
treated
wood
in
hive
construction
is
added
to
the
label
such
as,
"
Wood
treated
with
TCMTB
shall
not
be
used
in
the
construction
of
beehives."
This
study
is
a
combination
of
Guidelines
171­
4
and
850.3030
(
see
information
regarding
residue
data
requirements
for
uses
in
beehives
in
the
residue
chemistry
section
of
40
CFR
part
158).
Numbers
of
bees
used
in
this
study
and
methods
for
collection/
introduction
of
bees
into
hives,
feeding,
and
observations
for
toxicity
and
mortality
should
be
consistent
with
those
described
in
OPPTS
Guideline
850.3030,
"
Honey
Bee
Toxicity
of
Residues
on
Foliage."
The
toxicity
portion
of
this
study
is
in
lieu
of
the
honeybee
contact
LD50
test.

3.
Other
Labeling
Requirements
In
order
to
be
eligible
for
reregistration,
various
use
and
safety
information
will
be
included
in
the
labeling
of
all
end­
use
products
containing
TCMTB.
For
the
specific
labeling
statements
and
a
list
of
outstanding
data,
refer
to
Section
V
of
this
RED
document.

4.
Listed
Species
Considerations
a.
The
Endangered
Species
Act
Section
7
of
the
Endangered
Species
Act,
16
U.
S.
C.
Section
1536(
a)(
2),
requires
all
federal
agencies
to
consult
with
the
National
Marine
Fisheries
Service
(
NMFS)
for
marine
and
anadromous
listed
species,
or
the
United
States
Fish
and
Wildlife
Services
(
FWS)
for
listed
wildlife
and
freshwater
organisms,
if
they
are
proposing
an
"
action"
that
may
affect
listed
species
or
their
designated
habitat.
Each
federal
agency
is
required
under
the
Act
to
insure
that
any
58
action
they
authorize,
fund,
or
carry
out
is
not
likely
to
jeopardize
the
continued
existence
of
a
listed
species
or
result
in
the
destruction
or
adverse
modification
of
designated
critical
habitat.
To
jeopardize
the
continued
existence
of
a
listed
species
means
"
to
engage
in
an
action
that
reasonably
would
be
expected,
directly
or
indirectly,
to
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
the
species."
50
C.
F.
R.
§
402.02.

To
facilitate
compliance
with
the
requirements
of
the
Endangered
Species
Act
subsection
(
a)(
2)
the
Environmental
Protection
Agency,
Office
of
Pesticide
Programs
has
established
procedures
to
evaluate
whether
a
proposed
registration
action
may
directly
or
indirectly
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
any
listed
species
(
U.
S.
EPA
2004).
After
the
Agency's
screening­
level
risk
assessment
is
performed,
if
any
of
the
Agency's
Listed
Species
LOC
Criteria
are
exceeded
for
either
direct
or
indirect
effects,
a
determination
is
made
to
identify
if
any
listed
or
candidate
species
may
co­
occur
in
the
area
of
the
proposed
pesticide
use.
If
determined
that
listed
or
candidate
species
may
be
present
in
the
proposed
use
areas,
further
biological
assessment
is
undertaken.
The
extent
to
which
listed
species
may
be
at
risk
then
determines
the
need
for
the
development
of
a
more
comprehensive
consultation
package
as
required
by
the
Endangered
Species
Act.

For
certain
use
categories,
the
Agency
assumes
there
will
be
minimal
environmental
exposure,
and
only
a
minimal
toxicity
data
set
is
required
(
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
1/
23/
04,
Appendix
A,
Section
IIB,
pg.
81).
Chemicals
in
these
categories
therefore
do
not
undergo
a
full
screening­
level
risk
assessment,
and
are
considered
to
fall
under
a
no
effect
determination.
The
active
ingredient
uses
of
TCMTB,
with
the
exception
of
the
seed
treatment
and
antisapstain
wood
preservation
uses,
fall
into
this
category.
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
seed
treatment
risks
to
Listed
Species
were
not
identified.
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
antisapstain
wood
preservation
uses
of
TCMTB,
risks
to
Listed
Species
are
indicated.
Since
the
model
is
only
intended
as
a
screening­
level
model,
and,
as
such,
has
inherent
uncertainties
and
limitations
which
may
result
in
inaccurate
exposure
estimations,
further
refinement
of
the
model
is
recommended
before
any
regulatory
action
is
taken
regarding
the
antisapstain
uses
of
TCMTB.
Additionally,
impacts
from
the
antisapstain
use
could
potentially
be
mitigated
with
precautions
to
prevent
leaching
and
runoff
when
wood
is
stored
outdoors
(
see
General
Risk
Mitigation,
below).
Due
to
these
circumstances,
the
Agency
defers
making
a
determination
for
the
antisapstain
uses
of
TCMTB
until
additional
data
and
modeling
refinements
are
available.
At
that
time,
the
environmental
exposure
assessment
of
the
antisapstain
use
of
TCMTB
will
be
revised,
and
the
risks
to
Listed
Species
will
be
reconsidered.

b.
General
Risk
Mitigation
TCMTB
end­
use
products
(
EPs)
may
also
contain
other
registered
pesticides.
Although
the
Agency
is
not
proposing
any
mitigation
measures
for
products
containing
TCMTB
specific
to
federally
listed
species,
the
Agency
needs
to
address
potential
risks
from
other
end­
use
products.
Therefore,
the
Agency
requires
that
users
adopt
all
listed
species
risk
mitigation
measures
for
all
active
ingredients
in
the
product.
If
a
product
contains
multiple
active
ingredients
with
59
conflicting
listed
species
risk
mitigation
measures,
the
more
stringent
measure(
s)
should
be
adopted.
60
V.
What
Registrants
Need
to
Do
The
Agency
has
determined
that
TCMTB
is
eligible
for
reregistration
provided
that:
(
i)
additional
data
that
the
Agency
intends
to
require
confirm
this
decision;
(
ii)
the
risk
mitigation
measure
outlined
in
this
document
is
adopted;
and
(
iii)
label
amendments
are
made
to
reflect
this
measure.
To
implement
the
risk
mitigation
measure,
the
registrants
must
amend
their
product
labeling
to
incorporate
the
label
statement
set
forth
in
the
Label
Changes
Summary
Table
in
Section
B
below
(
Table
24).
The
additional
data
requirements
that
the
Agency
intends
to
obtain
will
include,
among
other
things,
submission
of
the
following:

For
TCMTB
technical
grade
active
ingredient
products,
the
registrant
needs
to
submit
the
following
items:

Within
90
days
from
receipt
of
the
generic
data
call­
in
(
DCI):

1.
Completed
response
forms
to
the
generic
DCI
(
i.
e.,
DCI
response
form
and
requirements
status
and
registrant's
response
form);
and
2.
Submit
any
time
extension
and/
or
waiver
requests
with
a
full
written
justification.

Within
the
time
limit
specified
in
the
generic
DCI:

1.
Cite
any
existing
generic
data
which
address
data
requirements
or
submit
new
generic
data
responding
to
the
DCI.

Please
contact
K.
Avivah
Jakob
at
(
703)
305­
1328
with
questions
regarding
generic
reregistration.

By
US
mail:
By
express
or
courier
service:

Document
Processing
Desk
Document
Processing
Desk
K.
Avivah
Jakob
K.
Avivah
Jakob
Office
of
Pesticide
Programs
Office
of
Pesticide
Programs
(
7510P)
(
7510P)
U.
S.
Environmental
Protection
Agency
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Ave.,
NW
One
Potomac
Yard,
Room
S­
4900
Washington,
DC
20460­
0001
2777
South
Crystal
Drive
Arlington,
VA
22202
61
For
end­
use
products
containing
the
active
ingredient
TCMTB,
the
registrant
needs
to
submit
the
following
items
for
each
product.

Within
90
days
from
the
receipt
of
the
product­
specific
data
call­
in
(
PDCI):

1.
Completed
response
forms
to
the
PDCI
(
i.
e.,
PDCI
response
form
and
requirements
status
and
registrant's
response
form);
and
2.
Submit
any
time
extension
or
waiver
requests
with
a
full
written
justification.

Within
eight
months
from
the
receipt
of
the
PDCI:

1.
Two
copies
of
the
confidential
statement
of
formula
(
EPA
Form
8570­
4);

2.
A
completed
original
application
for
reregistration
(
EPA
Form
8570­
1).
Indicate
on
the
form
that
it
is
an
"
application
for
reregistration";

3.
Five
copies
of
the
draft
label
incorporating
all
label
amendments
outlined
in
Table
23
of
this
document;

4.
A
completed
form
certifying
compliance
with
data
compensation
requirements
(
EPA
Form
8570­
34);

5.
If
applicable,
a
completed
form
certifying
compliance
with
cost
share
offer
requirements
(
EPA
Form
8570­
32);
and
6.
The
product­
specific
data
responding
to
the
PDCI.

Please
contact
Marshall
Swindell
at
(
703)
308­
6341
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
Document
Processing
Desk
Marshal
Swindell
Marshal
Swindell
Office
of
Pesticide
Programs
(
7510P)
Office
of
Pesticide
Programs
(
7510P)
U.
S.
Environmental
Protection
Agency
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Ave.,
NW
Room
S­
4900,
One
Potomac
Yard
Washington,
DC
20460­
0001
2777
South
Crystal
Drive
Arlington,
VA
22202
62
A.
Manufacturing
Use
Products
1.
Additional
Generic
Data
Requirements
The
generic
database
supporting
the
reregistration
of
TCMTB
has
been
reviewed
and
determined
to
be
substantially
complete.
However,
the
following
additional
data
requirements
have
been
identified
by
the
Agency
as
confirmatory
data
requirements
and
are
included
in
the
generic
data
call
in
(
DCI)
for
this
RED.

Data
must
be
submitted
indicating
whether
the
use
of
TCMTB,
as
an
antimicrobial
materials
preservative,
in
pulp
and
papermaking
will
result
in
residues
of
2­
MBT
in
paper.
The
registrant
must
also
provide
information
regarding
the
level
of
2­
MBT
that
will
occur
in
paper.
Application
rates
(
ranges)
on
all
TCMTB
paper
coating
use
labels
must
be
identified/
clarified.

The
risk
assessment
noted
deficiencies
in
the
surrogate
inhalation
exposure
data
available
from
the
Chemical
Manufacturers
Association
(
CMA)
data
base.
Therefore,
the
Agency
is
requiring
confirmatory
data
to
support
the
uses
assessed
with
the
CMA
exposure
data
within
this
risk
assessment.
The
risk
assessment
also
noted
that
many
of
the
use
parameters
(
e.
g.,
amount
handled
and
duration
of
use)
were
base
on
professional
judgments.
Therefore,
descriptions
of
human
activities
associated
with
the
uses
assessed
are
required
as
confirmatory.

The
requested
environmental
fate
and
ecological
studies
outline
in
Table
24
are
data
gaps
for
the
seed
treatment
and/
or
wood
preservative
uses
of
TCMTB.

Table
24.
Data
Requirements
for
TCMTB
Guideline
Study
Name
New
OPPTS
Guideline
Number
Old
Guideline
Number
Anaerobic
soil
metabolism
835.4200
162­
2
Terrestrial
field
dissipation
835.6100
164­
1
Aquatic
Field
Study
835.6200
164­
2
Aquatic
Invertebrate
Life­
Cycle
Study
850.1400
72­
4b
Life
Cycle
Fish
Study
850.1500
72­
5
Terrestrial
Plant
Toxicity,
Tier
I
(
seedling
emergence)
850.4100
122­
1a
Seedling
emergence,
Tier
II
850.4225
123­
1
Vegetative
vigor
with
Rice,
Tier
II
850.4250
123­
1
Aquatic
Plant
Growth,
Tier
II
850.5400
123­
2
Plant
Metabolism
860.1300
171­
4a
Residue
Analytical
Methods­
Plant
Commodities
860.1340
171­
4c
Storage
Stability
Data­
Plant
Commodities
860.1380
171­
4e
Processed
Food/
Feed­
Barley
860.1520
171­
4l
Processed
Food/
Feed­
Beet,
Sugar
860.1520
171­
4l
Processed
Food/
Feed­
Cotton
860.1520
171­
4l
Processed
Food/
Feed­
Oat
860.1520
171­
4l
63
Processed
Food/
Feed­
Rice
860.1520
171­
4l
Processed
Food/
Feed­
Safflower
860.1520
171­
4l
Processed
Food/
Feed­
Wheat
860.1520
171­
4l
Proposed
Tolerances
860.1550
171­
6
Submittal
of
Analytical
Reference
Standards
860.1650
171­
13
Dermal
Indoor
Exposure
875.1200
233
Inhalation
Indoor
Exposure
875.1400
234
Description
of
Human
Activity
875.2800
133­
1
Leather
Leaching
Data
Special
Study
Special
Study
Residues
in
honey/
beeswax
and
toxicity
of
treated
wood
residues
to
bees
No
Guideline
No
Guideline
Reserved
Confirmatory
Data
Requirements
for
Reregistration
Terrestrial
Plant
Toxicity,
Tier
II
(
seedling
emergence)
850.4225
123­
1
Livestock
Metabolism
860.1300
171­
4b
Residue
Analytical
Methods­
Livestock
Commodities
860.1340
171­
4d
Multi­
residue
Methods
860.1360
171­
4m
Storage
Stability
Data­
Processed
Commodities
860.1380
171­
4e
Storage
Stability
Data­
Livestock
Commodities
860.1380
171­
4e
Meat,
Milk,
Poultry,
and
Eggs
860.1480
171­
4i
Crop
Field
Trials­
Beat,
Sugar,
Tops
(
Root
and
Tuber
Vegetables
Group)
860.1500
171­
4k
Crop
Field
Trials­
Beet,
Sugar,
Tops
(
Leaves
of
Root
and
Tuber
Vegetables
Group)
860.1500
171­
4k
Crop
Field
Trials­
Barley,
Grain
(
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Oat,
Grain
(
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Rice,
Grain
(
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Wheat,
Grain
and
Aspirated
Grain
Fractions
(
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Barley,
Hay
and
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Oat,
Forage,
Hay
and
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Rice,
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
860.1500
171­
4k
64
Crop
Field
Trials­
Wheat,
Forage,
Hay,
and
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
860.1500
171­
4k
Crop
Field
Trials­
Cotton,
Undelinted
Seed
and
Gin
Byproducts
(
Miscellaneous
Commodities)
860.1500
171­
4k
Confined
Rotational
Crops
860.1850
165­
1
Field
Rotational
Crops
860.1900
165­
2
2.
Labeling
for
Technical
and
Manufacturing
Use
Products
To
ensure
compliance
with
FIFRA,
technical
and
manufacturing­
use
product
(
MP)
labeling
should
be
revised
to
comply
with
all
current
EPA
regulations,
PR
Notices
and
applicable
policies.
The
Technical
and
MP
labeling
should
bear
the
labeling
contained
in
Table
25,
Label
Changes
Summary
Table.

B.
End­
Use
Products
1.
Additional
Product­
Specific
Data
Requirements
Section
4(
g)(
2)(
B)
of
FIFRA
calls
for
the
Agency
to
obtain
any
needed
product­
specific
data
regarding
the
pesticide
after
a
determination
of
eligibility
has
been
made.
The
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
will
be
issued
at
a
later
date.

2.
Labeling
for
End­
Use
Products
Labeling
changes
are
necessary
to
implement
measures
outlined
in
Section
IV
above.
Specific
language
to
incorporate
these
changes
is
specified
in
Table
25,
Label
Changes
Summary
Table.

Registrants
may
generally
distribute
and
sell
products
bearing
old
labels/
labeling
for
26
months
from
the
date
of
the
issuance
of
this
Reregistration
Eligibility
Decision
document.
Persons
other
than
the
registrant
may
generally
distribute
or
sell
such
products
for
52
months
from
the
approval
of
labels
reflecting
the
mitigation
described
in
this
RED.
However,
existing
stocks
time
frames
will
be
established
case­
by­
case,
depending
on
the
number
of
products
involved,
the
number
of
label
changes,
and
other
factors.
Refer
to
"
Existing
Stocks
of
Pesticide
Products;
Statement
of
Policy,"
Federal
Register,
Volume
56,
No.
123,
June
26,
1991.

a.
Label
Changes
Summary
Table
In
order
to
be
eligible
for
reregistration,
all
product
labels
must
be
amended
to
incorporate
the
risk
mitigation
measure
outlined
in
Section
IV
of
the
TCMTB
RED.
The
following
table
describes
how
language
on
the
labels
should
be
amended.
65
Table
25.
Labeling
Changes
Summary
Table
Description
Amended
Labeling
Language
Placement
on
Label
Environmental
Hazards
Statements
Required
by
the
RED
and
Agency
Label
Policies
"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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
End
Use
Products
Intended
for
Occupational
Use
PPE
Requirements
"
Wear
chemical
resistant
gloves
while
handling
concentrate."
Immediately
following/
below
Precautionary
Statements:
Hazards
to
Humans
and
Domestic
Animals
For
all
antisapstain
end­
use
products
"
Treated
lumber
must
be
stored
under
cover,
indoors,
or
at
least
100
feet
from
any
pond,
lake,

stream,
wetland,
or
river
to
prevent
possible
runoff
of
the
product
into
the
waterway.
Treated
lumber
stored
within
100
feet
of
a
pond,
lake,
steam,
or
river
must
be
either
covered
with
plastic
or
surrounded
by
a
berm
to
prevent
surface
water
runoff
into
the
nearby
waterway.
If
a
berm
or
curb
is
used
around
the
site,
it
should
consist
of
impermeable
material
(
clay,
asphalt,

concrete)
and
be
of
sufficient
height
to
prevent
runoff
during
heavy
rainfall
events."
This
language
is
to
be
included
in
the
Environmental
Hazards
section
of
the
label.

Directions
For
Use
Use
Cancellation
All
TCMTB
textile
materials
preservative/
additive
incorporation
uses
are
cancelled
and
must
be
deleted
from
current
product
labels,
with
the
exception
use
on
leather.
Examples
of
cancelled
textiles
are
carpets,
fibers
and
cordage.

Use
Cancellation
All
TCMTB
paint
preservation/
application
uses
are
cancelled
and
must
be
deleted
from
all
product
labels.
66
VI.
APPENDICES
67
Appendix
A.
Table
of
Use
Patterns
for
TCMTB
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Materials
preservatives
Leather
Soluble
Concentrate
1448­
55
1448­
81
1448­
377
1448­
412
Add
to
pickling
liquor
or
tanning
liquor
at
the
start
of
the
tanning
process
or
to
the
rinse
water
in
a
post
tanning
refloat
The
dosage
level
used
will
depend
on
storage
conditions
and
the
length
of
protection
required.

A
dosage
rate
of
0.025­
0.3%

(
250­
2,000
ppm)
can
be
used.

A
satisfactory
dilution
of
1
part
solution
to
5
parts
water
can
be
prepared.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
68
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Leather
1448­
386
1448­
102
1448­
100
1448­
376
1448­
408
1.5
to
12.0
lbs
per
1,000
lbs
of
white
weight
stock.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
69
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Soluble
concentrate
1448­
55
1448­
81
1448­
99
1448­
100
1448­
377
0.1
to
3%
based
on
the
dry
weight
of
the
wood.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Particle
Board
1448­
386
Mix
with
resin
or
binding
agent
0.6
to
6.0%
based
on
the
dry
weight
of
the
wood.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
70
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Coatings,

caulkingsealants
&
wall
cover
adhesives,

pigment
slurries,

non
food
adhesives
Soluble
concentrate
1448­
45
1448­
55
1448­
81
1448­
99
1448­
100
1448­
102
1448­
376
1448­
377
44392­
11
Incorporation
(
mixing)
0.5
to
36%
based
on
the
total
formulation
weight.

For
solvent
based
formulations
use
combinations
of
aromatic
and
aliphatic
solvents.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
TCMTB
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
paint
preservation/
application
uses
are
cancelled
and
must
be
deleted
from
all
product
labels.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Textiles
Soluble
concentrate
1448­
55
Impregnate
Apply
solution
to
an
emulsion
of
convenient
concentration
of
1­
5%
impregnate
into
the
fabric
using
conventional
padding
or
sizing
equipment
Per
TCMTB
RED
mitigation,
all
TCMTB
textile
materials
preservative/
additive
incorporation
uses
are
cancelled
and
must
be
deleted
from
current
product
labels,
with
the
exception
of
use
on
leather.
Examples
of
cancelled
textiles
are
carpets,
fibers
and
cordage.
71
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Crude
and
refined
oils
Soluble
concentrate
1448­
81
1448­
99
1448­
100
1448­
102
1448­
147
1448­
148
1448­
171
1448­
172
1448­
376
1448­
386
1448­
377
44392­
11
Incorporation
Chemical
should
be
added
to
the
oil
as
it
is
being
transferred
from
the
shipping
container
to
the
storage
tank
at
a
rate
of
0.6
to
32
fl
oz
per
1,000
gal
of
oil.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Hides
and
skins
Soluble
concentrate
1448­
55
1448­
81
1448­
99
1448­
102
1448­
376
1448­
377
1448­
408
1448­
412
None
stated
The
solution
should
be
used
at
a
level
of
0.003%
to
0.02%

(
30
to
200ppm)
based
on
the
weight
of
the
green
fleshed
hides
or
skins
and
saturated
brine
solution.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
72
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Fuels
Soluble
concentrate
1448­
102
1448­
148
1448­
147
1448­
171
1448­
172
44392­
11
Incorporation
125
to
25
fl
oz
per
100
gallons
of
fuel.

­
or­

3.0
to
6.0
fl
oz
per
1,000
gal
of
fuel.
Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
73
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Bacteriostatic
paper
Soluble
concentrate
1448­
81
1448­
377
None
stated
Dosage:
0.
5%
to
9.0%

weight/
weight
of
product
and
added
at
the
size
press
or
similar
application.
The
bacteriostatic
paper
and
paperboard
applications
are
not
to
be
used
in
the
manufacture
of
food
contact
paper,

paper
coatings
or
paperboard.

Per
TCMTB
RED
mitigation,
occupational
handlers
of
antimicrobial
materials
preservative
products
must
wear
PPE
chemical
resistant
gloves
while
handling
concentrate.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
74
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Industrial
processes
and
water
systems
Pulp
mills
Soluble
concentrate
1448­
45
1448­
55
1448­
81
1448­
99
1448­
100
1448­
102
1448­
376
1448­
383
1448­
377
1448­
386
Spray
Applicator
rolls
0.5
to
12.0
lb
per
ton
of
oven
dry
wood
(
50
to
400
ppm).

It
can
be
applied
through
a
water
shower
located
in
the
pneumatic
conveyor
carrying
chips
from
the
chipper
to
the
storage
pile.

To
control
bacteria
and
fungal
growth
on
paper
and
paper
board
machines
add
to
the
white
water
or
stock
0.1
to
12.0
lb/
ton
of
dry
paper.

To
make
mold
resistant
paper
or
paperboard
use
at
0.05
to
0.6lb/
1000
sq
ft.

For
coated
paper
or
board,
the
solution
is
incorporated
in
the
coating
mix
prior
to
application.

For
uncoated
paper
or
board,

the
solution
is
dispersed
in
water,
surface
sizing
solution,

or
other
solvent
and
applied
to
the
surface
to
be
protected
by
means
of
applicator
roller.

For
mulch
paper
1.5
to
5lb/
ton
air
dry
paper.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
75
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Soluble
concentrate
1448­
55
1448­
81
1448­
147
1448­
148
1448­
149
1448­
150
1448­
377
Initial
dose:

0.6
to
3.7
fl
oz
per
1,000
gallons
of
water
in
the
system.

Subsequent
dose:

0.2
to
1.2
fl
oz
per
1,000
gallons
should
be
made
every
1
to
5
days.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Cooling
Water
1448­
100
1448­
152
1448­
153
1448­
386
1448­
408
Fill,
Flush
Fill,
Flush
3.6
to
22.2
fl
oz.
per
1,000
gallons
of
water.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
76
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Cooling
Water
1448­
99
1448­
102
1448­
151
1448­
171
1448­
172
1448­
244
1448­
376
1448­
383
44392­
11
1.3
to
14.8
fl
oz
per
1,000
gallons
of
water.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Drilling
Fluids
Soluble
concentrate
1448­
55
1448­
81
1448­
99
1448­
100
1448­
102
1448­
147
1448­
148
1448­
149
1448­
150
1448­
151
1448­
152
1448­
153
1448­
171
1448­
172
1448­
376
1448­
383
1448­
386
1448­
377
1448­
408
44392­
11
Incorporation
in
the
drilling
fluid.
0.05%
to
1.5
%
based
on
the
total
wet
weight
of
the
fluid.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
77
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Petroleum
Secondary
Recovery
Soluble
concentrate
1448­
55
1448­
81
1448­
99
1448­
100
1448­
102
1448­
147
1448­
148
1448­
149
1448­
150
1448­
151
1448­
152
1448­
153
1448­
171
1448­
172
1448­
376
1448­
383
1448­
386
1448­
377
1448­
244
44392­
11
Continuous
feed
method
Intermittent
feed
Slug
feed
0.2
to
6.3
fl
oz
per
100
gallons
of
Water.

0.65
to
10
fl
oz
per
1,000
gallons
of
water
4
to
8
hrs
per
day.

1.3
to
13.0
fl
oz
per
1,000
gallons
of
water
every
1
to
7
days,

15.6
to
52.0
fl
oz
per
1000
gallons
of
water
every
1
to
7
days.
78
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Cutting
fluids
Soluble
concentrate
1448­
55
1448­
99
1448­
100
1448­
149
1448­
150
1448­
151
1448­
152
1448­
153
1448­
386
1448­
265
1448­
244
Incorporation
Solution
should
be
added
to
diluted
cutting
fluid
at
a
rate
that
will
provide
150
to
1,500
ppm.

To
prevent
fungal
growth,

concentrations
of
1,000
to
7,500ppm
are
necessary.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Waste
water
treatment
systems
Soluble
concentrate
1448­
55
None
stated
The
quantity
of
solution
required
varies
with
the
degree
of
fouling.

It
should
be
added
at
a
rate
that
will
provide
10
to
30
ppm
of
the
waste
water.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
79
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Wood
Preservatives
Sapstain
Control
1448­
55
1448­
81
Dipping/
Pressure
Impregnation
0.5
to
8
gal
of
product
(
10%

TCMB)
per
100
gal
of
water.
Treatment
should
be
made
within
24
hrs
of
cutting
or
sawing.

Per
RED
mitigation,
the
following
language
must
appear
on
all
products
with
an
antisapstain
use:

"
Treated
lumber
must
be
stored
under
cover,
indoors,
or
at
least
100
feet
from
any
pond,
lake,
stream,
wetland,
or
river
to
prevent
possible
runoff
of
the
product
into
the
waterway.
Treated
lumber
stored
within
100
feet
of
a
pond,
lake,
steam,
or
river
must
be
either
covered
with
plastic
or
surrounded
by
a
berm
to
prevent
surface
water
runoff
into
the
nearby
waterway.
If
a
berm
or
curb
is
used
around
the
site,
it
should
consist
of
impermeable
material
(
clay,
asphalt,
concrete)
and
be
of
sufficient
height
to
prevent
runoff
during
heavy
rainfall
events."

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
80
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Sapstain
Control
1448­
102
Dipping/
Pressure
Impregnation
5.6
kg
to
44.0
kg
of
product
(
5%
TCMB)
per
100
liters
of
water.
Treatment
should
be
made
within
24
hrs
of
cutting
or
sawing.

Per
RED
mitigation,
the
following
language
must
appear
on
all
products
with
an
antisapstain
use:

"
Treated
lumber
must
be
stored
under
cover,
indoors,
or
at
least
100
feet
from
any
pond,
lake,
stream,
wetland,
or
river
to
prevent
possible
runoff
of
the
product
into
the
waterway.
Treated
lumber
stored
within
100
feet
of
a
pond,
lake,
steam,
or
river
must
be
either
covered
with
plastic
or
surrounded
by
a
berm
to
prevent
surface
water
runoff
into
the
nearby
waterway.
If
a
berm
or
curb
is
used
around
the
site,
it
should
consist
of
impermeable
material
(
clay,
asphalt,
concrete)
and
be
of
sufficient
height
to
prevent
runoff
during
heavy
rainfall
events."

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
81
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Sapstain
Control
1448­
100
1448­
99
Dipping/
Pressure
Impregnation
1.5
to
48
gal
of
product
(
5
to
10%
TCMB)
per
100
gal
of
water.
Treatment
should
be
made
within
24
hrs
of
cutting
or
sawing.

Per
RED
mitigation,
the
following
language
must
appear
on
all
products
with
an
antisapstain
use:

"
Treated
lumber
must
be
stored
under
cover,
indoors,
or
at
least
100
feet
from
any
pond,
lake,
stream,
wetland,
or
river
to
prevent
possible
runoff
of
the
product
into
the
waterway.
Treated
lumber
stored
within
100
feet
of
a
pond,
lake,
steam,
or
river
must
be
either
covered
with
plastic
or
surrounded
by
a
berm
to
prevent
surface
water
runoff
into
the
nearby
waterway.
If
a
berm
or
curb
is
used
around
the
site,
it
should
consist
of
impermeable
material
(
clay,
asphalt,
concrete)
and
be
of
sufficient
height
to
prevent
runoff
during
heavy
rainfall
events."

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
82
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Vertical
Wood
Surfaces,
roofs
and
sidewalls
56156­
1
Brush
or
low
pressure
sprayer
Sidewalls
 
first
coat:
100
sq.

ft.
per
gallon,
second
coat
200
sq
ft.
per
gallon
Roofs
 
75
to
150
sq.
ft.
per
gallon
depending
on
porosity
of
surface.

VOC
Content
limit:
less
than
500
grams
per
liter
or
4.6
lbs.

per
gallon
Do
not
apply
this
product
in
a
way
that
will
contact
workers
or
other
persons.

Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Cooling
Tower
Wood
1448­
55
1448­
81
Brush
or
periodic
shock
dose
Brush:
0.5
to
0.7%
of
product
in
water
onto
surface.

(
provides
0.6
to
0.8
lbs
per
1000
sq.
ft.
of
wood
surface)

Shock
Dose:
1.25
lb
of
product
per
1000
gallons
of
water.
Bleedoff
should
be
stopped
for
4
to
6
hrs
after
treatment.
Repeat
shock
treatment
every
four
months.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
83
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
1448­
302
Brush
or
periodic
shock
dose
Brush:
2.0
to
2.8%
of
product
in
water
onto
surface.

(
provides
2.4
to
3.2
lbs
per
1000
sq.
ft.
of
wood
surface)

Shock
Dose:
5.0
lb
of
product
per
1000
gallons
of
water.

Bleedoff
should
be
stopped
for
4
to
6
hrs
after
treatment.

Repeat
shock
treatment
every
four
months.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Cooling
Tower
Wood
1488­
100
Brush
or
periodic
shock
dose
Brush:
3.0
to
4.2%
of
product
in
water
onto
surface.

(
provides
3.6
to
4.8
lbs
per
1000
sq.
ft.
of
wood
surface)

Shock
Dose:
7.5
lb
of
product
per
1000
gallons
of
water.

Bleedoff
should
be
stopped
for
4
to
6
hrs
after
treatment.

Repeat
shock
treatment
every
four
months.
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
84
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Seed
Treatment
Barley
Seed,
Oat
Seed,
Rice
Seed,

Wheat
Seed
Liquid­
Concentrate
2935­
389
Commercial
treater
Maximum
application
rate:

0.026
lbs
ai/
100
lbs
of
seed
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."

Cotton
Liquid­
Concentrate
264­
965
264­
983
2935­
413
2935­
389
Commercial
treater
On­
farm
treater
Maximum
application
rate
(
commercial
treater):

0.13
lbs
ai/
100
lbs
of
seed
Maximum
application
rate
(
on­
farm
treater):

0.051
lbs
ai/
100
lbs
of
seed
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
85
Use
Site
Formulation/

EPA
No.
Method
of
Application
Application
Rate/
No.

of
applications
Use
Limitations
Safflower
Seed,

Sugar
beet
Seed
Liquid­
Concentrate
2935­
389
Commercial
treater
Maximum
application
rate:

0.041
lbs
ai/
100
lbs
of
seed
Per
TCMTB
RED
mitigation,
all
TCMTB
labels
must
state
the
following:

"
This
product
is
toxic
to
fish,
aquatic
invertebrates,
oysters
and
shrimp.
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."
86
Appendix
B.
Table
of
Generic
Data
Requirements
and
Studies
Used
to
Make
the
Reregistration
Decision
Guide
to
Appendix
B
Appendix
B
contains
listing
of
data
requirements
which
support
the
reregistration
for
active
ingredients
within
case
#
2625(
TCMTB)
covered
by
this
RED.
It
contains
generic
data
requirements
that
apply
to
TCMTB
in
all
products,
including
data
requirements
for
which
a
"
typical
formulation"
is
the
test
substance.

The
data
table
is
organized
in
the
following
formats:

1.
Data
Requirement
(
Column
1).
The
data
requirements
are
listed
in
the
order
in
which
they
appear
in
40
CFR
part
158.

The
reference
numbers
accompanying
each
test
refer
to
the
test
protocols
set
in
the
Pesticide
Assessment
Guidance,
which
are
available
from
the
National
technical
Information
Service,
5285
Port
Royal
Road,
Springfield,
VA
22161
(
703)
487­
4650.

2.
Use
Pattern
(
Column
4).
This
column
indicates
the
use
patterns
for
which
the
data
requirements
apply.
The
following
letter
designations
are
used
for
the
given
use
patterns.

(
1)
Agricultural
premises
and
equipment
(
2)
Food
handling/
storage
establishments'
premises
and
equipment
(
3)
Commercial,
institutional
and
industrial
premises
and
equipment
(
4)
Residential
and
public
access
premises
(
5)
Medical
premises
and
equipment
(
6)
Human
water
systems
(
7)
Materials
preservatives
(
8)
Industrial
processes
and
water
systems
(
9)
Antifouling
coatings
(
10)
Wood
preservatives
(
11)
Swimming
pools
(
12)
Aquatic
areas
3.
Bibliographic
Citation
(
Column
5).
If
the
Agency
has
acceptable
data
in
its
files,
this
column
list
the
identify
number
of
each
study.
This
normally
is
the
Master
Record
Identification
(
MRID)
number,
but
may
be
a
"
GS"
number
if
no
MRID
number
has
been
assigned.
Refer
to
the
Bibliography
appendix
for
a
complete
citation
of
the
study.
87
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
PRODUCT
CHEMISTRY
830.1550
61­
1
Product
Identity
and
Composition
1,3,
4,
7,8,10
41612001
830.1600
830.1620
830.1650
61­
2a
Starting
Materials
and
Manufacturing
Process
1,3,
4,
7,8,10
41612001
830.1670
61­
2b
Formation
of
Impurities
1,3,
4,
7,8,10
41612001
830.1700
62­
1
Preliminary
Analysis
1,3,
4,
7,8,10
41612002
830.1750
62­
2
Certification
of
Limits
1,3,
4,
7,8,10
41612002
830.1800
62­
3
Analytical
Method
1,3,
4,
7,8,10
41612002
830.6302
63­
2
Color
1,3,
4,
7,8,10
41612003
830.6303
63­
3
Physical
State
1,3,
4,
7,8,10
41612003
830.6304
63­
4
Odor
1,3,
4,
7,8,10
41612003
830.7220
63­
6
Boiling
Point
1,3,
4,
7,8,10
41612003,
42407401
830.7300
63­
7
Density
1,3,
4,
7,8,10
41612003
830.7840
830.7860
63­
8
Solubility
1,3,
4,
7,8,10
42059701,
41612003
830.7950
63­
9
Vapor
Pressure
1,3,
4,
7,8,10
41612003,
42059701
830.7550
830.7560
830.7570
63­
11
Partition
Coefficient
(
Octanol/
Water)
1,3,
4,
7,8,10
4232450,4205970,
41612003
830.7000
63­
12
pH
1,3,
4,
7,8,10
41612003
830.6313
63­
13
Stability
1,3,
4,
7,8,10
41612003
830.6314
63­
14
Oxidizing/
Reducing
Action
1,3,
4,
7,8,10
41612003
830.6315
63­
15
Flammability
1,3,
4,
7,8,10
41612003
88
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
830.6316
63­
16
Explodability
1,3,
4,
7,8,10
41612003
830.6317
63­
17
Storage
Stability
1,3,
4,
7,8,10
41612003
830.7100
63­
18
Viscosity
1,3,
4,
7,8,10
41612003
830.6319
63­
19
Miscibility
1,3,
4,
7,8,10
41612003
830.6320
63­
20
Corrosion
Characteristics
1,3,
4,
7,8,10
41612003
830.6321
63­
21
Dielectric
breakdown
voltage
1,3,
4,
7,8,10
41612003
ECOLOGICAL
EFFECTS
850.2100
71­
1a
Avian
Acute
Oral
Toxicity
Test
Quail/
Duck
1,3,
4,
7,8,10
41780901
850.2100
71­
1b
Avian
Acute
Oral
Toxicity
Test
Quail/
Duck
TEP
1,3,
4,
7,8,10
41780901
850.2200
71­
2a
Avian
Acute
Dietary
Toxicity
Quail
1,3,
4,
7,8,10
41595602,
42428501
850.2200
71­
2b
Avian
Dietary
Toxicity
Duck
1,3,
4,
7,8,10
41595601
850.1075
72­
1a
Fish
Acute
Toxicity
 
Freshwater
Bluegill
1,3,
4,
7,8,10
41804201
850.1075
72­
1c
Fish
Toxicity
Rainbow
Trout
1,3,
4,
7,8,10
41818101
850.1010
72­
2a
Acute
Aquatic
Invertebrate
Toxicity
1,3,
4,
7,8,10
41838201,
42226001
850.1075
72­
3a
Acute
Estuarine/
Marine
Toxicity
­
Fish
1,3,
4,
7,8,10
40363601
72­
3b
Acute
Estuarine/
Marine
Toxicity
­
Invertebrate
(
Mollusk)
1,3,
4,
7,8,10
40363603
850.1025
72­
3c
Estuarine/
Marine
Toxicity
­
Invertebrate
(
Shrimp)
1,3,
4,
7,8,10
40363602
850.1300
72­
4a
Fish
Early
Life­
Stage
Testing
1,3,
4,
7,8,10
425929­
01
850.1400
72­
4b
Aquatic
Invertebrate
Life­
Cycle
1,3,
4,
7,8,10
Data
Gap
850.1500
72­
5
Life
Cycle
Fish
1,3,
4,
7,8,10
Data
Gap
850.1710
72­
6
Aquatic
Org.
Accumulation
1,3,
4,
7,8,10
42418501,
46705201,
42453201
89
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
850.4100
122­
1a
Terrestrial
Plant
Toxicity,
Tier
I
(
seeding
emergence)
1,3,
4,
7,8,10
Data
Gap
850.4400
123­
2
Aquatic
Vascular
Plant
Toxicity,
Tier
II
1,3,
4,
7,8,10
442009­
01
850.5400
123­
2
Aquatic
Plant
Growth,
Tier
II
1,3,
4,
7,8,10
Data
Gap
850.4225
123­
1
Seedling
Emergence­
Tier
II
1,3,
4,
7,8,10
Data
Gap
850.4250
123­
1
Vegetative
Vigor
with
Rice­
Tier
II
1,3,
4,
7,8,10
Data
Gap
875.2100
132­
1a
Foliar
Residue
Dissipation
 
not
an
eco
requirement,
check
with
fate/
residue
chem
1,3,
4,
7,8,10
Waived
None
None
Honey
Bee
Wood
Preservative
Residues
Test
1,3,
4,
7,8,10
Data
Gap
(
Unless
label
statement
prohibiting
use
for
beehive
construction
is
added)

TOXICOLOGY
870.1100
81­
1
Acute
Oral
­
Rat
1,3,
4,
7,8,10
41583801
870.1200
81­
2
Acute
Dermal
­
Rabbit
1,3,
4,
7,8,10
41515401
870.1300
81­
3
Acute
Inhalation
­
Rat
1,3,
4,
7,8,10
40419301,
41640601
870.2400
81­
4
Primary
Eye
Irritation
­
Rabbit
1,3,
4,
7,8,10
Acc.
No.
111991
870.2500
81­
5
Primary
Dermal
Irritation
­
Rabbit
1,3,
4,
7,8,10
41583701
870.2600
81­
6
Dermal
Sensitization
1,3,
4,
7,8,10
42349201,
Acc
No.
259676
82­
1a
90­
Day
Feeding­
Rodent
1,3,
4,
7,8,10
41342201
870.3100
82­
1b
90­
Day
Feeding­
Non­
Rodent
1,3,
4,
7,8,10
41342201
870.3200
82­
2
21/
28­
Day
Dermal
Toxicity
 
Rat/
Rabbit
1,3,
4,
7,8,10
41655801
870.3465
82­
4
90­
Day
Inhalation
Toxicity
1,3,
4,
7,8,10
Reserved
870.3700
83­
3
Developmental
Toxicity
1,3,
4,
7,8,10
00154295,
Accession
no.
260491,

40075102
90
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
870.3800
83­
4
Reproduction
and
Fertility
Effects
­
2
Generation
Repro
Rat
1,3,
4,
7,8,10
41471401
83­
1a
Chronic
Feeding
Toxicity
­
Rodent
1,3,
4,
7,8,10
41342201
870.4100
83­
1b
Chronic
Feeding
Toxicity
­
Non­
Rodent
1,3,
4,
7,8,10
41342201
83­
2a
Oncogenicity
­
Rat
1,3,
4,
7,8,10
42383001
870.4200
83­
2b
Oncogenicity
­
Mouse
1,3,
4,
7,8,10
42383001
870.3700a
83­
3a
Teratogenicity­
Rat
1,3,
4,
7,8,10
00154295,
accession
no.
260491
870.3700b
83­
3b
Teratogenicity­
Rabbit
1,3,
4,
7,8,10
40075102
870.4300
83­
5
Combined
Chronic
Toxicity/
Carcinogenicity
in
Rats
1,3,
4,
7,8,10
42116301,
41529701,
41570301
870.5100
84­
2
Mutagenicity
study­
Gene
mutation
1,3,
4,
7,8,10
41386101
870.5395
84­
2
Mutagenicity
C
Mammalian
erythrocyte
micronucleus
1,3,
4,
7,8,10
00165520
870.5550
84­
4
Rat
Primary
Hepatocyte
Unscheduled
DNA
Synthesis
Assay
1,3,
4,
7,8,10
00165518
870.7485
85­
1
General
Metabolism
1,3,
4,
7,8,10
40884801
(
upgradeable)

The
study
does
not
fulfill
the
complete
requirements
for
a
metabolism
study,
as
incomplete
identification
of
metabolites
and
the
purity
of
TCMTB
was
not
reported.

Only
a
single
low
does
and
a
single
high
does
were
tested,
a
repeated
does
is
required.

OCCUPATIONAL/
RESIDENTIAL
EXPOSURE
875.2800
133­
1
Description
of
Human
Activity
1,3,
4,
7,8,10
Data
Gap
875.2400
875.2900
133­
3
Dermal
Passive
Dosimetry
1,3,
4,
7,8,10
Waived
875.1200
875.1600
233
Dermal
Indoor
Exposure
1,3,
4,
7,8,10
Data
Gap
91
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
875.1400
875.1600
234
Inhalation
Indoor
Exposure
1,3,
4,
7,8,10
Data
Gap
ENVIRONMENTAL
FATE
835.2120
161­
1
Hydrolysis
1,3,
4,
7,8,10
Upgradeable
42386101,
43437601
835.2240
161­
2
Photodegradation­
water
1,3,
4,
7,8,10
42630901
835.2410
161­
3
Photodegradation­
soil
1,3,
4,
7,8,10
41515701
835.4100
162­
1
Aerobic
Soil
Metabolism
1,3,
4,
7,8,10
Upgradeable
435322­
01
835.4200
162­
2
Anaerobic
Soil
Metabolism
1,3,
4,
7,8,10
Data
Gap
835.4400
162­
3
Anaerobic
Aquatic
Metabolism
1,3,
4,
7,8,10
428154­
01
835.4300
162­
4
Aerobic
Aquatic
Metabolism
1,3,
4,
7,8,10
Upgradeable
425086­
01
835.1240
163­
1
Leach/
Adsorption/
Desorption
1,3,
4,
7,8,10
426314­
01
835.1240
163­
1
Soil
Column
Leaching
1,3,
4,
7,8,10
Data
Gap
835.6100
164­
1
Terrestrial
Field
Dissipation
1,3,
4,
7,8,10
Data
Gap
835.6200
164­
2
Aquatic
Field
Study
1,3,
4,
7,8,10
Data
Gap
850.1730
165­
4
Accumulation
Studies
in
Fish
1,3,
4,
7,8,10
424185­
01,
424932­
01,
467052­
01
RESIDUE
CHEMISTRY
860.1100
171­
2
Chemical
Identity
1,3,
4,
7,8,10
41612001
860.1300
171­
4
Plant
Metabolism
1,3,
4,
7,8,10
Data
Gap
860.1300
171­
4
Livestock
Metabolism
1,3,
4,
7,8,10
Reserved
860.1340
171­
4
Residue
Analytical
Methods­
Plant
Commodities
1,3,
4,
7,8,10
Data
Gap
92
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
860.1340
171­
4
Residue
Analytical
Method­
Livestock
1,3,
4,
7,8,10
Reserved
860.1360
171­
4
Multi­
residue
Methods
1,3,
4,
7,8,10
Reserved
860.1380
171­
4
Storage
Stability
Data­
Plant
Commodities
1,3,
4,
7,8,10
Data
Gap
860.1380
171­
4
Storage
Stability
Data­
Processed
Commodities
1,3,
4,
7,8,10
Reserved
860.1380
171­
4
Storage
Stability
Data­
Livestock
Commodities
1,3,
4,
7,8,10
Reserved
860.1480
171­
4i
Meat/
Milk/
Poultry/
Egg
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Beat,
Sugar,
Tops
(
Root
and
Tuber
Vegetables
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Beet,
Sugar,
Tops
(
Leaves
of
Root
and
Tuber
Vegetables
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Barley,
Grain
(
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Oat,
Grain
(
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Rice,
Grain
(
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Wheat,
Grain
and
Aspirated
Grain
Fractions
(
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Barley,
Hay
and
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Oat,
Forage,
Hay
and
Straw
(
Fodder,
Forage,

Hay
and
Straw
of
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Rice,
Straw
(
Fodder,
Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Wheat,
Forage,
Hay,
and
Straw
(
Fodder,

Forage,
Hay
and
Straw
of
Cereal
Grains
Group)
1,3,
4,
7,8,10
Reserved
860.1500
171­
4k
Crop
Field
Trials­
Cotton,
Undelinted
Seed
and
Gin
Byproducts
(
Miscellaneous
Commodities)
1,3,
4,
7,8,10
Reserved
860.1520
171­
4l
Processed
Food/
Feed­
Barley
1,3,
4,
7,8,10
Data
Gap
860.1520
171­
4l
Processed
Food/
Feed­
Beet,
Sugar
1,3,
4,
7,8,10
Data
Gap
860.1520
171­
4l
Processed
Food/
Feed­
Cotton
1,3,
4,
7,8,10
Data
Gap
93
DATA
REQUIREMENT
CITATION(
S)

New
Guideline
Number
Old
Guideline
Number
Study
Title
Use
Pattern
MRID
Number
860.1520
171­
4l
Processed
Food/
Feed­
Oat
1,3,
4,
7,8,10
Data
Gap
860.1520
171­
4l
Processed
Food/
Feed­
Rice
1,3,
4,
7,8,10
Data
Gap
860.1520
171­
4l
Processed
Food/
Feed­
Safflower
1,3,
4,
7,8,10
Data
Gap
860.1520
171­
4l
Processed
Food/
Feed­
Wheat
1,3,
4,
7,8,10
Data
Gap
860.1550
171­
6
Proposed
Tolerances
1,3,
4,
7,8,10
Data
Gap
860.1650
171­
13
Submittal
of
Analytical
Reference
Standards
1,3,
4,
7,8,10
Data
Gap
860.1850
165­
1
Confined
Rotational
Crops
1,3,
4,
7,8,10
Reserved
860.1900
165­
2
Field
Rotational
Crops
1,3,
4,
7,8,10
Reserved
OTHER
DATA
REQUIREMENTS
Special
Study
Special
Study
Leather
Leaching
Study
1,3,
4,
7,8,10
Data
Gap
94
Appendix
C.
Technical
Support
Documents
Additional
documentation
in
support
of
this
RED
is
maintained
in
the
OPP
docket,
located
in
Room
S­
4400,
One
Potomac
Yard,
2777
South
Crystal
Drive,
Arlington,
VA,
and
is
open
Monday
through
Friday,
excluding
legal
holidays,
from
8:
30
am
to
4
pm.

The
docket
initially
contained
the
April
19,
2006
preliminary
risk
assessment
and
the
related
documents.
EPA
then
considered
comments
on
these
risk
assessments
(
which
are
posted
to
the
e­
docket)
and
revised
the
risk
assessments.
The
revised
risk
assessments
will
be
posted
in
the
docket
at
the
same
time
as
the
RED.

All
documents,
in
hard
copy
form,
may
be
viewed
in
the
OPP
docket
room
or
downloaded
or
viewed
via
the
Internet
at
the
following
site:

http://
www.
regulations.
gov
These
documents
include:

 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
(
Phase
3
of
4­
Phase
Process);
Notice
of
Availability,
4/
26/
2006
Preliminary
Risk
Assessment
and
Supporting
Science
Documents:
 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Preliminary
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,
04/
19/
2006.
 
TCMTB.
Acute
and
Chronic
Dietary
Exposure
Assessments
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,
02/
28/
2006.
Samuel
Ary.
 
TCMTB.
Summary
of
Analytical
Chemistry
and
Residue
Data
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,
2/
28/
2006.
Samuel
Ary.
 
Incident
Reports
Associated
with
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB),
04/
18/
2006.
Jonathan
Chen.
 
Environmental
Fate
Assessment
of
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,
03/
30/
2006.
Srinivas
Gowda.
 
Product
Chemistry
Science
Chapter
for
2­(
Benzpthiazolylthio)
methly
thiocyanate,
03/
31/
2006.
Chris
Jiang.
 
Drinking
Water
Assessment
for
the
Use
of
the
Fungicide
of
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
as
a
Seed
Treatment
on
Cotton,
Wheat,
Barley,
Oats,
Rice,
Sugar
Beets,
and
Safflower,
07/
31/
2006.
James
Lin.
 
Aquatic
Exposure
Assessment
for
the
Use
of
the
Fungicide
of
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
as
a
Seed
Treatment
on
Cotton,
Wheat,
Barley,
Oats,
Rice,
Sugar
Beets,
and
Safflower,
02/
16/
2006.
James
Lin
 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)­
Report
of
the
Antimicrobials
Division
Toxicity
Endpoint
Selection
Committee
(
ADTC),
04/
19/
2006.
Timothy
F.
McMahon.
 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Ecological
Hazard
and
Environmental
Risk
Characterization
and
Environmental
Modeling
Chapters
for
the
Reregistration
Eligibility
Decision
(
RED)
Document
(
D322613),
Edited
per
Phase
I
Error
Correction
95
Comments
and
Revised
ESA
Language,
04/
06/
2006.
Kathryn
Montague.
 
TCMTB
[
2­(
Thiocyanomethylthio)
benzothiazole]:
First
Revision
of
the
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document.
04/
06/
2006,
Charles
Smith.
 
Toxicology
Disciplinary
Chapter
for
the
Reregistration
Eligibility
Decision
(
RED)
Risk
Assessment,
04/
04/
2006.
Deborah
Smegal.
 
Occupational
and
Residential
Exposure
Assessment
for
2­
(
Thiocyanomethylthio)
benzothiazole
TCMTB,
04/
18/
2006.
Siroos
Mostaghimi.

Revised
Risk
Assessment
and
Supporting
Science
Documents
(
RED
Supporting
Documents):
 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document,
08/
01/
2006.
 
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
Ecological
Hazard
and
Environmental
Risk
Assessment
Chapter­
Revised,
08/
01/
2006.
Kathryn
Montague
 
TCMTB
[
2­(
Thiocyanomethylthio)
benzothiazole]:
Second
Revision
of
the
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document,
07/
27/
2006.
Charles
Smith
96
Appendix
D.
Citations
Considered
to
be
Part
of
the
Data
Base
Supporting
the
Reregistration
Decision
(
Bibliography)

1.
MRID
Studies
MRID#
Citation
00004239
Wilbur­
Ellis
Company
(
1979)
Residue
Data
Summary.
Unpublished
study
including
letter
dated
Oct
16,
1978
from
J.
H.
Stoner
to
Dave
T.
Schulteis,
received
Feb
6,
1979
under
2935­
413;
pre­
pared
in
cooperation
with
Stoner
Laboratories;
CDL:
237334­
A
00004241
Wilbur­
Ellis
Company
(
1979)
Results
of
Tests
on
the
Amount
of
Resi­
due
Remaining,
Including
a
Description
of
the
Analytical
Method:
Nu­
Flow
ND.
Unpublished
study
received
Feb
6,
1979
under
2935­
413;
CDL:
237335­
B.

00046073
Buckman
Laboratories,
Incorporated
(
1975)
Analytical
Procedures
and
Results
of
Residue
Analyses:
Busan
30.
Undated
method.
Unpublished
study
received
Nov
12,
1976
under
7F1885;
CDL:
095601­
D.

00078556
Buckman
Laboratories,
Incorporated
(
1972)
Analytical
Procedures
and
Results
of
Residue
Analyses:
Busan
30.
Includes
undated
methods
entitled:
Analyses
of
2­(
thiocyanomethylthio)
benzothiazole
in
soil;
Regulatory
method
of
analysis.
Unpublished
study
re­
ceived
Mar
26,
1975
under
4F1613;
CDL:
095525­
F.

00112618
Buckman
Laboratories,
Inc.
(
1970)
Results
of
Tests
on
the
Amount
of
Residue
Remaining,
Including
a
Description
of
the
Analytical
Method:
2­
(
Thiocyanomethylthio)
benzothiazole.
Compilation;
unpublished
study
received
on
unknown
date
under
0F0954;
CDL:
091624­
K.

00117874
Buckman
Laboratories,
Inc.
(
1967)
Study:
TCMTB
Residues
in
Selected
Grains).
(
Compilation;
unpublished
study
received
Sep
28,
1972
under
2F1264;
CDL:
091795­
A.

00124027
Buckman
Laboratories,
Inc.
(
19??)
Analysis
of
Grains
for
Thioben­
zothiazole­
Containing
Residues.
Unpublished
study
received
Oct
20,
1972
under
2F1264;
CDL:
094858­
A.

00136342
Buckman
Laboratories,
Inc.
(
19??)
Analysis
of
Grains
for
Thioben­
zothiazole­
Containing
Residues.
Unpublished
study
received
on
unknown
date
under
2F1264;
CDL:
097967­
A.
97
MRID#
Citation
00138078
Buckman
Laboratories,
Inc.
(
1975)
Residue
Data:
Busan
30:
Sugar
Cane.
Unpublished
study
received
Nov
12,
1976
under
7F1885;
CDL:
097566­
B.

00154295
Goad
P.
T.,
et
al.
1985.
Teratogenicity
study
of
TCMTB
in
rats.
HED
Doc
no.
005769.

165518
Bonner,
G.
(
1986)
Evaluation
of
Other
Genotoxic
Effects
TCMTB
(
EPA
Reg.
No.:
1448­
29):
In
the
Rat
Primary
Hepatocyte
Unscheduled
DNA
Synthesis
Assay:
HBC
Project
No.
20991.
Unpublished
study
prepared
by
Hazleton
Biotechnologies
Company.
21
p.

165520
Bonner,
G.
(
1986)
Evaluation
for
Structural
Chromosomal
Aberration
of
TCMTB
(
EPA
Reg.
No.:
1448­
29):
Clastogenic
Evaluation
in
the
in
vivo
Mouse
Micronucleus
Assay:
HBC
Project
No.
20996.
Unpublished
study
prepared
by
Hazleton
Biotechnologies
Co.
23
p.

009869
Booden,
R.
M.
1974.
Avian
Dietary
LC50,
Mallard
Duck,
Report
#
4043620.
Unpublished
data,
conducted
by
Warf
Institute
for
Buckman
Laboratories,
Memphis,
TN.

091624
Knott,
W.
B.,
and
G.
Woodard.
1968a.
Busan
72
 
Safety
Evaluation
on
Bobwhite
Quail.
Unpublished
data,
conducted
by
Woodard
Research
Corp.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN.

091624
Knott,
W.
B.,
and
G.
Woodard.
1968b.
Busan
72
 
Safety
Evaluation
on
Bluegill
Sunfish
and
Rainbow
Trout.
Unpublished
data,
conducted
by
Woodard
Research
Corp.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN
400751­
01
Adam,
C.
P.
1986.
TCMTB 
A
teratology
study
in
rabbits.

400751­
02
Adam,
C.
P.
1986.
TCMTB 
A
teratology
study
in
rabbits.

403636­
01
Surprenant,
D.
C.
1986a.
Acute
Toxicity
of
TCMTB
to
the
Sheepshead
Minnow,
Cyprinodon
variegatus.
Unpublished
data,
conducted
by
Springborn
Bionomics,
Inc.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN
403363­
02
Surprenant,
D.
C.
1987.
Acute
Toxicity
of
TCMTB
to
Mysid
Shrimp
(
Mysidopsis
bahia).
Unpublished
data,
conducted
by
Springborn
Bionomics,
Inc.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN.
98
MRID#
Citation
403636­
03
Surprenant,
D.
C.
1986b.
Acute
Toxicity
of
TCMTB
to
Embryo­
Larvae
of
the
Quahog
Clam
(
Mercenaria
mercenaria).
Unpublished
data,
conducted
by
Springborn
Bionomics,
Inc.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN.
404193­
01
Buckman
Laboratories,
Inc.
(
1987)
Submission
of
Toxicity
Data
on
TCMTB
in
support
of
EPA
Reg.
No.
1448­
29.
Transmittal
of
1
study.

408848­
01
Cameron,
B.
D.
Scott,
G.
1987.
The
Metabolism
of
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
in
the
rat.
Buckman
Laboratories,
Inc.,
Memphis
TN.
Inveresk
Research
International
Ltd.,
Scotland
413422­
01
Goburdhun,
R.,
and
Greenough,
R.
J.
1989.
2­
(
Thiocyanomethylthio)
benzothiazole
(
TCMTB):
52­
Week
dietary
toxicity
study
in
dogs.

413861­
01
Lawlor,
T.;
Respess,
C.
(
1990)
Mutagenicity
Test
on
TCMTB
in
the
Salmonella/
Mammalian­
microsome
Reverse
Mutation
Assay
(
Ames
Test)
with
Confirmatory
Assay:
Final
Report:
Lab
Project
I.
D.:
110277­
0­
401R.
Unpublished
study
prepared
by
Hazleton
Labora­
tories
America,
Inc.
32p.

414714­
01
Hazelden,
K.,
Pl.
and
Wilson,
J.
A.
1988.
TCMTB­
Two
generation
reproduction
study
in
rats.
HED
Doc
010607
415154­
01
Hazleton­
Institut
Francais
de
Toxicologie
(
1990)
TCMTB
Technical
Grade:
Acute
Dermal
Median
Lethal
Dose:
Lab
Project
Number:
410211.
48
p.

415157­
01
Saxena,
A.
(
1987)
Artificial
Sunlight
Photodegradation
of
TCMTB
in
a
Buffered
Aqueous
Solution:
Lab
Project
Number:
HLA
6015­
335.
Unpublished
study
prepared
by
Hazleton
Laboratories
America,
Inc.
86
p.

415297­
01
Everett,
D.
J.
et
al.
1989.
104­
Week
dietary
toxicity/
carcinogenicity
study
n
rats
with
52­
week
interim
kill.

415703­
01
Everett,
D.
J.
et
al.
1989.
104­
Week
dietary
toxicity/
carcinogenicity
study
n
rats
with
52­
week
interim
kill.

415837­
01
Rush,
R.
(
1990)
Primary
Skin
Irritation
Study
in
Rabbits
with
TCMTB
­
80
(...):
Lab
Project
Number:
3138.61.
Unpublished
study
pre­
pared
by
Springborn
Laboratories,
Inc.
20
p.
99
MRID#
Citation
415838­
01
Rush,
R.
(
1990)
Acute
Oral
Toxicity
Study
in
Rats
with
TCMTB­
80
(..
.):
Lab
Project
Number:
3138.59.
Unpublished
study
prepared
by
Springborn
Laboratories,
Inc.
63
p.

415956­
01
Long,
R.
D.,
C.
P.
Driscoll,
K.
A.
Hoxter,
and
G.
J.
Smith.
1990.
TCMTB:
A
Dietary
LC50
Study
with
the
Mallard.
Unpublished
data,
conducted
by
Wildlife
International,
Ltd.,
for
Buckman
Laboratories,
Inc.,
Memphis,
TN.

415956­
02
Long,
R.
D.,
C.
P.
Driscoll,
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(
http://
www.
epa.
gov/
oppefed1/
models/
terrestrial).

Tier
1
models:
GENEEC
(
version
2.0;
Aug.
1,
2001)
and
SCI­
GROW
(
version
2.3;
Nov.
4,
2003)
screening
models.
http://
www.
epa.
gov/
oppefed1/
models/
water/.

USEPA.
2000.
Information
on
Assessing
Exposure
from
Pesticides,
"
A
User's
Guide."
http://
www.
epa.
gov/
fedrgstr/
EPA­
PEST/
2000/
July/
Day­
12/
6061.
pdf
USEPA.
2004.
PBT
Profiler:
Assessing
Chemicals
in
the
Absence
of
Data,
v1.203.
http://
www.
pbtprofiler.
net/
default.
asp.
(
January
2006).

4.
Internal
Documents
and
Models
USEPA.
1979.
TN
2432.
Biological
Report
of
Analysis,
90+
TCMTB,
sample
MB618.
Unpublished
data,
performed
by
US
EPA
Terrestrial
and
Aquatic
Biology
Laboratory.

USEPA.
1979.
TN
2427.
Biological
Report
of
Analysis,
90+
TCMTB,
sample
MB618.
106
Unpublished
data,
performed
by
US
EPA
Terrestrial
and
Aquatic
Biology
Laboratory.

USEPA.
1980.
TN
2437.
Biological
Report
of
Analysis,
90+
TCMTB,
sample
MB618.
Unpublished
data,
performed
by
US
EPA
Terrestrial
and
Aquatic
Biology
Laboratory.

USEPA.
1997.
Exposure
Factors
Handbook.
Volume
I­
II.
Office
of
Research
and
Development.
Washington,
D.
C.
EPA/
600/
P­
95/
002Fa.
August
1997.

USEPA.
1998.
PHED
Surrogate
Exposure
Guide.
Estimates
of
Worker
Exposure
from
the
Pesticide
Handler
Exposure
Database
Version
1.1.
Washington,
DC:
U.
S.
Environmental
Protection
Agency.

USEPA.
1999.
Evaluation
of
Chemical
Manufacturers
Association
Antimicrobial
Exposure
Assessment
Study
(
Amended
on
8
December
1992).
Memorandum
from
Siroos
Mostaghimi,
PH.
D.,
USEPA
to
Julie
Fairfax,
USEPA.
Dated
November,
4
1999.
DP
Barcode
D247642.

USEPA.
2000.
Residential
SOPs.
EPA
Office
of
Pesticide
Programs
Human
Health
Effects
Division.
Dated
April
5,
2000.

USEPA.
2000.
Information
on
Assessing
Exposure
from
Pesticides,
"
A
User's
Guide."
http://
www.
epa.
gov/
fedrgstr/
EPA­
PEST/
2000/
July/
Day­
12/
6061.
pdf
USEPA.
2001.
HED
Science
Advisory
Council
for
Exposure.
Policy
Update,
November
12.
Recommended
Revisions
to
the
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessment,
February
22,
2001.

USEPA,
March
2,
2004.
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
(
HED
ExpoSAC)
SOP
#
15:
"
Amount
of
Seed
Treated
or
Planted
per
Day."

USEPA.
2004.
WLM
recommendation
regarding
chemical
generalization.
Memorandum
to
Siroos
Mostaghimi,
from
Lee
R.
December
15,
2004.

USEPA.
2004.
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
January
23,
2004.

USEPA,
2004.
Wood
Leaching
Model:
Chemical
Concentration
Screening
Tool,
v1.0.
USEPA/
OPPT/
AD,
developed
by
Versar,
Inc.

USEPA.
2004.
PBT
Profiler:
Assessing
Chemicals
in
the
Absence
of
Data,
v1.203.
http://
www.
pbtprofiler.
net/
default.
asp.
(
January
2006).

USEPA.
2006.
2­(
thiocyanomethylethylthio)
benzothaizole
(
TCMTB)­
report
of
the
107
Antimicrobials
Division
Toxicity
Endpoint
Selection
Committee
(
ADTC).
Memorandum
from
Timothy
McMahon
to
Deborah
Smegal.
April
4,
2006.

USEPA.
2006.
Office
of
Pesticide
Programs
internal
memorandum,
"
Aquatic
Exposure
Assessment
for
the
Use
of
the
Fungicide
of
2­(
Thiocyanomethylthio)
benzothiazole
(
TCMTB)
as
a
Seed
Treatment
on
Cotton,
Wheat,
Barley,
Oats,
Rice,
Sugar
Beets,
and
Safflower,"
February
16,
2006.

USEPA.
1/
11/
2006.
Deschamp,
P,"
Report
of
the
RARC."

Dietary
Exposure
Evaluation
Model
Software
with
the
Food
Commodity
Intake
Database
(
DEEM­
FCID
 
,
Version
2.03).

FDA
Center
for
Food
Safety
&
Applied
Nutrition's
(
CFSAN),
4/
2002.
"
Preparation
of
Food
Contact
Notifications
and
Food
Additive
Petitions
for
Food
Contact
Substances:
Chemistry
Recommendations."

FIRST
(
version
1.0;
Aug.
1,
2001)
Screening
Model.
http://
www.
epa.
gov/
oppefed1/
models/
water/
.

Terrestrial
Residue
Exposure
Model
(
TREX)
(
http://
www.
epa.
gov/
oppefed1/
models/
terrestrial).

Tier
1
models:
GENEEC
(
version
2.0;
Aug.
1,
2001)
and
SCI­
GROW
(
version
2.3;
Nov.
4,
2003)
screening
models.
http://
www.
epa.
gov/
oppefed1/
models/
water/.
108
Appendix
E.
Generic
Data
Call­
In
The
Agency
intends
to
issue
a
Generic
Data
Call­
In
at
a
later
date.
See
Chapter
V
of
the
TCMTB
RED
for
a
list
of
studies
that
the
Agency
plans
to
require.
109
Appendix
F.
Product
Specific
Data
Call­
In
The
Agency
intends
to
issue
a
Product
Specific
Data
Call­
In
at
a
later
date.
110
Appendix
G.
Batching
of
TCMTB
Products
for
Meeting
Acute
Toxicity
Data
Requirements
for
Reregistration
The
Agency
will
complete
the
batching
for
TCMTB
at
a
later
date.
111
Appendix
H.
List
of
All
Registrants
Sent
the
Data
Call­
In
A
list
of
registrants
sent
the
data
call­
in
will
be
posted
at
a
later
date.
112
Appendix
I.
List
of
Available
Related
Documents
and
Electronically
Available
Forms
Pesticide
Registration
Forms
are
available
at
the
following
EPA
internet
site:
http://
www.
epa.
gov/
opprd001/
forms/
.

Pesticide
Registration
Forms
(
These
forms
are
in
PDF
format
and
require
the
Acrobat
reader)

Instructions
1.
Print
out
and
complete
the
forms.
(
Note:
Form
numbers
that
are
bolded
can
be
filled
out
on
your
computer
then
printed.)

2.
The
completed
form(
s)
should
be
submitted
in
hardcopy
in
accord
with
the
existing
policy.

3.
Mail
the
forms,
along
with
any
additional
documents
necessary
to
comply
with
EPA
regulations
covering
your
request,
to
the
address
below
for
the
Document
Processing
Desk.

DO
NOT
fax
or
e­
mail
any
form
containing
`
Confidential
Business
Information'
or
`
Sensitive
Information.'

If
you
have
any
problems
accessing
these
forms,
please
contact
Nicole
Williams
at
(
703)
308­
5551
or
by
e­
mail
at
williams.
nicole@
epamail.
epa.
gov.

The
following
Agency
Pesticide
Registration
Forms
are
currently
available
via
the
internet
at
the
following
locations:
8570­
1
Application
for
Pesticide
Registration/
Amendment
http://
www.
epa.
gov/
opprd001/
forms/
8570­
1.
pdf
8570­
4
Confidential
Statement
of
Formula
http://
www.
epa.
gov/
opprd001/
forms/
8570­
4.
pdf
8570­
5
Notice
of
Supplemental
Registration
of
Distribution
of
a
Registered
Pesticide
Product
http://
www.
epa.
gov/
opprd001/
forms/
8570­
5.
pdf
8570­
17
Application
for
an
Experimental
Use
Permit
http://
www.
epa.
gov/
opprd001/
forms/
8570­
17.
pdf
8570­
25
Application
for/
Notification
of
State
Registration
of
a
Pesticide
To
Meet
a
Special
Local
Need
http://
www.
epa.
gov/
opprd001/
forms/
8570­
25.
pdf
8570­
27
Formulator's
Exemption
Statement
http://
www.
epa.
gov/
opprd001/
forms/
8570­
27.
pdf
8570­
28
Certification
of
Compliance
with
Data
Gap
Procedures
http://
www.
epa.
gov/
opprd001/
forms/
8570­
28.
pdf
8570­
30
Pesticide
Registration
Maintenance
Fee
Filing
http://
www.
epa.
gov/
opprd001/
forms/
8570­
30.
pdf
8570­
32
Certification
of
Attempt
to
Enter
into
an
Agreement
with
other
Registrants
for
Development
of
Data
http://
www.
epa.
gov/
opprd001/
forms/
8570­
32.
pdf
8570­
34
Certification
with
Respect
to
Citations
of
Data
(
in
PR
Notice
98­
5)
http://
www.
epa.
gov/
opppmsd1/
PR_
Notices/
pr98­
5.
pdf
8570­
35
Data
Matrix
(
in
PR
Notice
98­
5)
http://
www.
epa.
gov/
opppmsd1/
PR_
Notices/
pr98­
5.
pdf
8570­
36
Summary
of
the
Physical/
Chemical
Properties
(
in
PR
Notice
98­
1)
http://
www.
epa.
gov/
opppmsd1/
PR_
Notices/
pr98­
1.
pdf
8570­
37
Self­
Certification
Statement
for
the
Physical/
Chemical
Properties
(
in
PR
Notice
98­
1)
http://
www.
epa.
gov/
opppmsd1/
PR_
Notices/
pr98­
1.
pdf
113
Pesticide
Registration
Kit
www.
epa.
gov/
pesticides/
registrationkit/.

Dear
Registrant:

For
your
convenience,
we
have
assembled
an
online
registration
kit
that
contains
the
following
pertinent
forms
and
information
needed
to
register
a
pesticide
product
with
the
U.
S.
Environmental
Protection
Agency's
Office
of
Pesticide
Programs
(
OPP):

1.
The
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA)
as
Amended
by
the
Food
Quality
Protection
Act
(
FQPA)
of
1996.

2.
Pesticide
Registration
(
PR)
Notices
a.
83­
3
Label
Improvement
Program 
Storage
and
Disposal
Statements
b.
84­
1
Clarification
of
Label
Improvement
Program
c.
86­
5
Standard
Format
for
Data
Submitted
under
FIFRA
d.
87­
1
Label
Improvement
Program
for
Pesticides
Applied
through
Irrigation
Systems
(
Chemigation)

e.
87­
6
Inert
Ingredients
in
Pesticide
Products
Policy
Statement
f.
90­
1
Inert
Ingredients
in
Pesticide
Products;
Revised
Policy
Statement
g.
95­
2
Notifications,
Non­
notifications,
and
Minor
Formulation
Amendments
h.
98­
1
Self
Certification
of
Product
Chemistry
Data
with
Attachments
(
This
document
is
in
PDF
format
and
requires
the
Acrobat
reader.)

Other
PR
Notices
can
be
found
at
http://
www.
epa.
gov/
opppmsd1/
PR_
Notices.

3.
Pesticide
Product
Registration
Application
Forms
(
These
forms
are
in
PDF
format
and
will
require
the
Acrobat
reader.)

a.
EPA
Form
No.
8570­
1,
Application
for
Pesticide
Registration/
Amendment
b.
EPA
Form
No.
8570­
4,
Confidential
Statement
of
Formula
c.
EPA
Form
No.
8570­
27,
Formulator's
Exemption
Statement
d.
EPA
Form
No.
8570­
34,
Certification
with
Respect
to
Citations
of
Data
e.
EPA
Form
No.
8570­
35,
Data
Matrix
114
4.
General
Pesticide
Information
(
Some
of
these
forms
are
in
PDF
format
and
will
require
the
Acrobat
reader.)

a.
Registration
Division
Personnel
Contact
List
b.
Biopesticides
and
Pollution
Prevention
Division
(
BPPD)
Contacts
c.
Antimicrobials
Division
Organizational
Structure/
Contact
List
d.
53
F.
R.
15952,
Pesticide
Registration
Procedures;
Pesticide
Data
Requirements
(
PDF
format)

e.
40
CFR
Part
156,
Labeling
Requirements
for
Pesticides
and
Devices
(
PDF
format)

f.
40
CFR
Part
158,
Data
Requirements
for
Registration
(
PDF
format)

g.
50
F.
R.
48833,
Disclosure
of
Reviews
of
Pesticide
Data
(
November
27,
1985)

Before
submitting
your
application
for
registration,
you
may
wish
to
consult
some
additional
sources
of
information.
These
include:

1.
The
Office
of
Pesticide
Programs'
Web
Site
2.
The
booklet
"
General
Information
on
Applying
for
Registration
of
Pesticides
in
the
United
States",
PB92­
221811,
available
through
the
National
Technical
Information
Service
(
NTIS)
at
the
following
address:

National
Technical
Information
Service
(
NTIS)
5285
Port
Royal
Road
Springfield,
VA
22161
The
telephone
number
for
NTIS
is
(
703)
605­
6000.
Please
note
that
EPA
is
currently
in
the
process
of
updating
this
booklet
to
reflect
the
changes
in
the
registration
program
resulting
from
the
passage
of
the
FQPA
and
the
reorganization
of
the
Office
of
Pesticide
Programs.
We
anticipate
that
this
publication
will
become
available
during
the
Fall
of
1998.

3.
The
National
Pesticide
Information
Retrieval
System
(
NPIRS)
of
Purdue
University's
Center
for
Environmental
and
Regulatory
Information
Systems.
This
service
does
charge
a
fee
for
subscriptions
and
custom
searches.
You
can
contact
NPIRS
by
telephone
at
(
765)
494­
6614
or
through
their
Web
site.

4.
The
National
Pesticide
Telecommunications
Network
(
NPTN)
can
provide
information
on
active
ingredients,
uses,
toxicology,
and
chemistry
of
pesticides.
You
can
contact
NPTN
by
telephone
at
(
800)
858­
7378
or
through
their
Web
site:
ace.
orst.
edu/
info/
nptn.

The
Agency
will
return
a
notice
of
receipt
of
an
application
for
registration
or
amended
registration,
experimental
use
permit,
or
amendment
to
a
petition
if
the
applicant
or
petitioner
115
encloses
with
his
submission
a
stamped,
self­
addressed
postcard.
The
postcard
must
contain
the
following
entries
to
be
completed
by
OPP:

Date
of
receipt
EPA
identifying
number
Product
Manager
assignment
Other
identifying
information
may
be
included
by
the
applicant
to
link
the
acknowledgment
of
receipt
to
the
specific
application
submitted.
EPA
will
stamp
the
date
of
receipt
and
provide
the
EPA
identifying
File
Symbol
or
petition
number
for
the
new
submission.
The
identifying
number
should
be
used
whenever
you
contact
the
Agency
concerning
an
application
for
registration,
experimental
use
permit,
or
tolerance
petition.
To
assist
us
in
ensuring
that
all
data
you
have
submitted
for
the
chemical
are
properly
coded
and
assigned
to
your
company,
please
include
a
list
of
all
synonyms,
common
and
trade
names,
company
experimental
codes,
and
other
names
which
identify
the
chemical
(
including
"
blind"
codes
used
when
a
sample
was
submitted
for
testing
by
commercial
or
academic
facilities).
Please
provide
a
CAS
number
if
one
has
been
assigned.
