	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	WASHINGTON, D.C.  20460

                                   OFFICE OF PREVENTION, PESTICIDES

                                            AND TOXIC SUBSTANCES

MEMORANDUM 

TO:		Chloropicrin Reregistration Eligibility Decision (RED) Team

FROM:	Nathan Mottl, Reregistration Branch 1

Special Review and Reregistration Division

SUBJECT:	Revised Use Closure Memorandum for Chloropicrin, Chemical No.
081501

DATE:	June 6, 2005

As a result of the December 7, 2000 Smart Meeting on chloropicrin uses
and the update meeting held on June 29, 2004, this memorandum will act
as the Agency’s record of common understanding on the uses of
chloropicrin to be included in the risk assessment. This memo revises
the original use closure memo written by Kelly White on March 9, 2005
after the Agency received use pattern comments from the Chloropicrin
Manufacturers Task Force (CMTF) on April 22, 2005. 

Chloropicrin is used as an insecticide, nematicide, fungicide, and
herbicide.  Chloropicrin is phytotoxic, and is used to sterilize soil
prior to planting.  It is applied as a fumigant and can be applied
alone, with methyl bromide, or with Telone (e.g., 1,3-Dichloropropene). 
Chloropicrin is registered for pre-plant soil fumigation of land to be
planted with a wide variety of food, ornamental, and nursery crops. 
Chloropicrin uses are also being supported for the in-situ treatment of
wooden utility poles, piles and timber members.  The major use is for
utility poles; however, railroad structures are often treated with
chloropicrin as well.  

There are no food uses of chloropicrin.  All post-harvest food storage
area uses have been cancelled and the associated tolerances are being
revoked.  Chloropicrin is registered for use as a warning agent in
methyl bromide formulations for treating empty grain storage bins, but
this use is a non-food use that does not require a tolerance.     

The Chloropicrin Manufacturers Task Force (CMTF) is comprised of the
four companies that produce technical chloropicrin – Niklor Chemicals,
Inc., Arvesta Corporation, ASHTA Chemicals, Inc., and Trinity
Manufacturing, Inc.  Steptoe & Johnson L.L.P. represents the CMTF. 
Other chloropicrin registrants include:  Tri-Cal Chemicals, Great Lakes
Chemical, Osmose Railroad Services, Inc., Osmose Utility Services, Inc.,
Albemarle Corporation, Soil Chemical Corporation, Ameribrom Inc.,
Hendrix and Dail Inc., Reddick Fumigants, Inc., Shadow Mountain Products
Corporation, Holtrachem, and Dow AgroSciences LLC.  There are 60
products total – 6 technical formulations and 54 end-use products.

USES

Chloropicrin is registered as a pre-plant soil fumigant for land to be
planted with the following crops:

	

Berries: Caneberries, blackberries, boysenberries, dewberries,
loganberries, raspberries, youngberries, blueberries, cranberries,
gooseberries, huckleberries.

Small fruits: Strawberries, currants, grapes, kumquat, bananas, figs,
persimmons, pineapple, pomegranates, tree fruits (all), vine fruits
(all).

Citrus fruits: Grapefruit, lemon, limes, oranges, tangelos, tangerines.

Nut crops: Almonds, cashews, chestnuts, filberts, hickory nuts, pecans,
walnuts, pistachios

Pome and stone fruits: Apples, pears, quinces, apricots, cherries,
nectarines, peaches, plums, prunes, dates.  

Cucurbits: Melons (all), cantaloupes, casaba  melons, crenshaw melons,
honeydew, muskmelons, persian melons, watermelon, cucumbers, pumpkins,
squash (summer and winter), mango melons. 

Vegetables: asparagus, eggplant, peppers, pimentos, tomatoes, cole
crops, broccoli, Brussels sprouts, cabage, cauliflower, collards, kale,
kohlrabi, endive, lettuce (all), mustard, spinach, Swiss chard, carots,
garlic, leeks, okra, onions, parsnips, potatoes, radishes, rutabagas,
salsify, shallots, sweet potato, yams, popcorn, garden beets, celery,
turnips, vegetables (all).

Field crops: beans (all), peas (all), kenaf, forage-fodder grasses
(all), pastures, alfalfa, clover, lespedeza, vetch, birdsfoot trefoil,
barley, corn, oats, rye, sorghum, wheat, sugarcane, buckwheat, tobacco,
safflower, cotton, flax, peanuts, soybeans, millet.   

Ornamentals: golf course turf, ornamental turf, forest trees (all),
herbaceous plants (all), woody plants (all), flowering plants (all).

Miscellaneous: Hops, horseradish, mint, olives, greenhouse soils,
mushroom house soils.

Chloropicrin is used both as the sole active ingredient in chloropicrin
end-use formulations and as an active ingredient in end-use formulations
in which methyl bromide or Telone is also an active ingredient.  In
addition, chloropicrin is part of the end-use formulation for the
iodomethane soil fumigant, which is undergoing registration review.
Chloropicrin is also used as a warning agent with these soil fumigants
at levels of two percent or less by weight in the formulation.

cc:  Sara Beth Watson, Steptoe & Johnson L.L.P.

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