Reader’s Guide to the Chloropicrin E-Docket #OPP-2007-0350

EPA Requests Comment on Chloropicrin Risk Mitigation Options

EPA is seeking public comment on risk mitigation options for five soil
fumigant pesticides, including chloropicrin.  The Phase 5 comment
period for these pesticides opened May 2, 2007, and closes July 2, 2007.

	EPA’s goal in developing risk mitigation for the fumigants is to
reduce exposure to workers and bystanders below levels of concern, while
maintaining effective and economical use for agriculture.   

Purpose of This Reader’s Guide

	EPA has created this Reader’s Guide to provide an organizational
structure to the chloropicrin electronic docket (  HYPERLINK
"http://www.regulations.gov"  www.regulations.gov , docket number
EPA-HQ-OPP-2007-0350), to allow readers to more easily access and
navigate the various entries contained in the chloropicrin docket, and
to facilitate public comment.  Since chloropicrin is one of six soil
fumigants being evaluated at this time, its docket contains both
chloropicrin specific documents as well as other documents that address
mitigation options and risk management goals for the soil fumigants as a
group.  This document contains an annotated list, with docket entry
numbers and organized by subject matter, of all documents relevant to
the current Phase 5 public comment period for chloropicrin risk
management options.

	EPA has created this document to provide an organizational structure to
the chloropicrin e-docket.  The docket index lists the chloropicrin
items sequentially, while this document lists them by subject matter. 
The Agency is providing the “Reader’s Guide” to allow the reader
to more easily access and navigate the various items contained in the
chloropicrin e-docket.

 

Health Effects Associated with Chloropicrin 

	Chloropicrin poses risks for agricultural handlers and by-standers. 
Dietary exposure is not expected for the currently registered use
patterns.  EPA has considered the toxicity of chloropicrin to
agricultural handlers and bystanders.

	Acute exposure to chloropicrin causes eye, throat and nasal irritation,
eye tearing, and is corrosive to skin.   At higher doses, human incident
data are consistent with these findings.  Symptoms include itchy and
burning eyes, tearing, headaches, rash and burning skin, nausea,
scratchy throat, salivation, coughing, and shortness of breath. 

Key considerations as you review the chloropicrin risk assessment:

Much of the chloropicrin risk assessment focuses on bystander risk,
however EPA is also seeking comment on mitigation for occupational risk
to handlers (mixers, loaders, and applicators) and post application
workers.

EPA has considered multiple lines of evidence, using the best available
data including information from incidents, actual field monitoring
studies and modeling estimates.

EPA approached the risk assessments for chloropicrin and the other
fumigants differently from other agricultural pesticide risk
assessments.  Because the fumigants are converted to gases shortly after
application, exposures to workers and bystanders are largely through
inhalation.  Thus, new methods for estimating concentrations in air
through time and at various distances from the application site were
developed. 

EPA used an industry model, which relies on EPA’s long-used air
dispersion model, and provides distances at which air concentrations
reach or fall below a concentration that EPA has identified as a level
of concern.

Although the model (as do other industry-developed models) refers to
these outputs as “buffer zones,” they are in fact estimates of air
concentrations at various distances and should not be interpreted as a
decision regarding what mitigation measures (e.g., what specific size
buffer) will be required.

The risk assessments are designed to present risk estimates largely as a
broad spectrum of distances, representing different combinations of
applications factors, such as application rate, number of acres being
treated, type of application method used, and type of sealing method
used.

Later, in developing risk mitigation decisions, EPA will consider
modeling results, information from incidents, and air monitoring
studies, to select practical measures to reduce exposure to soil
fumigants. 

 

Benefits Assessments for Chloropicrin

	Chloropicrin is a commonly used soil fumigant because it can be mixed
with other fumigants at a low rate to act as a chemical warning agent or
used at higher rates to provide plant pathogen control in many crops. 
Chloropicrin is registered for use as a soil fumigant on all food, feed,
and fiber crops, including seedlings and ornamentals. Approximately 10
million pounds of chloropicrin are used annually
(http://www.epa.gov/oppsrrd1/reregistration/soil_fumigants/soil_fumigant
_use.pdf).  Major agricultural use sites with respect to percent crop
treated and total pounds are strawberries, tobacco, peppers, and
tomatoes.

  

	Typical applications are made prior to planting.  Chloropicrin may be
applied through drip irrigation or by injection below the soil surface
either in rows or broadcast across an area.  It may also be applied to
field or row crops during pre-plant stages by chemigation via drip line
sprinklers, soil broadcast, or row treatment through shank injection
treatment (deep or shallow).  Broadcast or row treatments may also be
tarped.

Key considerations as you review the Chloropicrin benefits assessments:

Benefits assessments for chloropicrin and other fumigants focus on
benefits of the chemicals as they are currently labeled and used.  The
assessments do not yet evaluate the possible impacts associated with the
range of mitigation options under consideration.

The “benefits” have been estimated by comparing the costs associated
with current use to those estimated for use of next best alternative(s).
 Assessments at this stage are limited to consideration of a
hypothetical situation in which new restrictions would make a grower’s
first choice of fumigant use for pest control less practical than use of
an alternative.

This approach helps EPA to understand the “worst case” and predict
possible consequences if new restrictions were to make the use of a
grower’s first choice pest control fumigant less feasible than the
next best alternative.  

EPA is particularly interested in receiving information on the economic
impact of various mitigation options in particular crops and locations
during this Phase 5 comment period.  

Later, in developing risk mitigation decisions, EPA will consider the
benefits of soil fumigant use and the predicted impacts of mitigation
options. 

 

Ecological Assessment for Chloropicrin

	Existing data used to assess ecological risks from exposure to
chloropicrin suggest that chloropicrin may pose risks to fish, aquatic
invertebrates, and non-target terrestrial animals including birds,
mammals and reptiles.  The environmental fate and ecological effects
assessment for chloropicrin has been revised based on the public
comments received by the Agency during the Phase 3 public comment
period.

 

Assessments for the Antimicrobial Uses of Chloropicrin

	Chloropicrin is used as a wood preservative typically for remedial
treatment of poles, and timbers.  This use poses risks to occupational
workers if they are not wearing proper personal protective equipment
(PPE).  Dietary risks and risks to non-occupational bystanders are not
expected for any antimicrobial uses.

Current Status and Next Steps

	The Phase 5 public comment period for chloropicrin and other soil
fumigants opened on May 2, 2007 and will close on July 2, 2007.  Phase 5
focuses on the development of risk management options.  EPA anticipates
considering comments and developing a risk management decision later
this year.  

How to Submit Comments

	Comments on risk mitigation options for chloropicrin and the other soil
fumigants must be submitted to EPA no later than July 2, 2007.  Submit
your comments, identified by docket number EPA-HQ-OPP-2007-0350, by one
of the following methods.  For additional information, see EPA’s May
2, 2007 Federal Register notice, Chloropicrin Revised Human Health Risk
Assessment, Notice of Availability, and Solicitation of Risk Reduction
Options.

Federal eRulemaking Portal,   HYPERLINK "http://www.regulations.gov" 
http://www.regulations.gov :  Follow the on-line instructions for
submitting comments.

Mail:  Office of Pesticide Programs (OPP), Regulatory Public Docket
(7502P), Environmental Protection Agency, 1200 Pennsylvania Avenue, NW,
Washington, DC 20460-0001.

Delivery:  OPP Regulatory Public Docket (7502P), Environmental
Protection Agency, Room S-4400, One Potomac Yard (South Building), 2777
S. Crystal Drive, Arlington, VA.  Deliveries are accepted only during
the Docket’s normal hours of operation (8:30 a.m. to 4:00 p.m., Monday
through Friday, excluding legal holidays).  Special arrangements should
be made for deliveries of boxed information.  The Docket telephone
number is 703-305-5805. 

Contact

	For additional information about EPA’s solicitation of risk reduction
options for chloropicrin, contact: 

Nathan Mottl

Special Review and Reregistration Division (7508P)

Office of Pesticide Programs

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460-0001

Telephone number: 703-305-0208

Federal Register and Docket Organizational Documents:

Docket Entry 1. Federal Register Notice: Chloropicrin Revised Risk
Assessments, Notice of Availability, and Solicitation of Risk Reduction
Options (Phase 5 of 6-Phase Process)

Docket Entry 2.  Reader’s Guide to Chloropicrin Docket #
OPP-2007-0350.

Special Review and Reregistration Division’s Documents

                                                                        
                                                               

Docket Entry 3. Risk Mitigation Options to Address Bystander and
Occupational Exposures from Soil Fumigant Applications.

Docket Entry 4. Chloropicrin Special Review and Reregistration Division
(SRRD) Response to Phase 3 Public Comments.

Health Effects Division Risk Assessment Documents

Docket Entry 5: Chloropicrin: Revised HED Human Health Assessment for
Phase 5.

Docket Entry 6: Memorandum:Response to Public Comments. The Health
Effects Response to Comments Phase 3.

Docket Entry 7: Chloropicrin: HED Response to Comments Submitted to the
Agency Concerning the Product Chemistry Chapter.

Docket Entry 8: Response to Comments Concerning Chloropicrin Incident
Report Phase III Comment Period for the Fumigant Chloropicrin.

Docket Entry 9: Summary Fumigants Group Incident Reports for DP Barcode
D326938,  Chemical #069005.

Docket Entry 10: Summary Fumigants Group Incident Reports for DP Barcode
D326938, Chemical #069005 and Other Data.

Docket Entry 11: Summary Fumigants Group Incident Reports for DP Barcode
D326938, Chemical #069005 and Other Data. (1) Epidemiologic Review of
General Comments and Technical Comments from PAN on Oct.12, 2005; and
(2) State of Washington Letter Incidents for Metam-Sodium D326938; PC
Code 039003 from Barbara Morrissey and Dorothy Tibbetts on October 20,
2005 

Docket Entry 12:  CD with supporting files for PERFUM modeling

	

Antimicrobial Division

Docket Entry 13: Revised Occupational and Residential/Bystander
Assessment of the Antimicrobial Use (Remedial Wood Treatment) of
Chloropicrin for the Reregistration Eligibility Decision (RED) Document
(Phase 3 Comment Period).  PC Code 081501, DP Barcode D314399.

Environmental Fate and Effects Division Risk Assessment Documents:

Docket Entry 14: Phase IV Level I Screening Ecological Risk Assessment
for the Reregistration of Chloropicrin.

Docket Entry 15: Memorandum: Response to Phase III Pubic Comments on the
Draft Environmental Fate and Ecological Risk Assessment.

Biological and Economic Analysis Division

Docket Entry 16: BEAD Responses to Public Comments on the Chloropicrin
Risk Assessment (Docket Number:  EPA-HQ-OPP-2006-0661).

Docket Entry 17: Summary of the Benefits of Soil Fumigation with
Chloropicrin in Crop Production (DP# 337501).

Docket Entry 18: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam-Sodium in Cucurbit Production
(DP# 337490).

Docket Entry 19: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Metam-Sodium, and Methyl Bromide in Eggplant Production
(DP# 337490).

Docket Entry 20: Assessment of the Benefits Soil Fumigants (Methyl
Bromide, Chloropicrin, Metam-Sodium, Dazomet) Used by Forest Tree
Seedling Nurseries.

Docket Entry 21: Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, Dazomet, and Metam Sodium for Use in
Raspberry Nurseries, Fruit and Nut Deciduous Tree Nurseries, and Rose
Bush Nurseries in California.

Docket Entry 22: Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam-sodium in Onion Production (DP # 337490).

Docket Entry 23: Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Grape Production 
(DP#337490).

Docket Entry 24: Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin and Metam Sodium in Tree Nut Production (DP
#337490).

Docket Entry 25: Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam Sodium in Pome Fruits Production (DP #337490).

Docket Entry 26: Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Stone Fruit Production
(DP #337490).

Docket Entry 27: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Bell Pepper Production
(DP #337490).

Docket Entry 28: Assessment of the Benefits of Soil Fumigation with
Metam Sodium in 

Potato Production (DP #337490).

Docket Entry 29: Assessment of Soil Fumigation with Chloropicrin, Methyl
Bromide and Metam-sodium in Strawberry Production.

Docket Entry 30: Assessment of the Benefits of Chloropicrin, Methyl
Bromide, Metam-sodium and Dazomet Use In Strawberry Nursery Runner
Production.

Docket Entry 31: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam-sodium on Sweet Potato
Production (DP# 337490).

Docket Entry 32: Assessment of the Benefits of Soil Fumigation with
Chloropicrin in Tobacco Production (DP# 337490).

Docket Entry 33: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Tomato Production (DP#
337490).

Docket Entry 34: Assessment of the Benefits of Soil Fumigation with
Metam-Sodium in Carrot Production (DP# 337490).

Docket Entry 35: Assessment of the Benefits of Soil Fumigation with
Metam Sodium in Peanut Production (DP# 337490).

Docket Entry 36: Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, Metam Sodium and Dazomet in Ornamental
Production.

Docket Entry 37: BEAD's Planned Impact Assessments on Agricultural Sites
with Significant Use of Soil Fumigants (Chloropicrin, Dazomet, Methyl
Bromide, Metam Potassium, and Metam Sodium.

 PAGE   

 PAGE   8 

For More Information on EPA’s Soil Fumigant Risk Mitigation Options
and Risk Management Goals: 

EPA-HQ-OPP-2007-0350-0003 – Risk Mitigation Options to Address
Bystander and Occupational Exposures from Soil Fumigant Applications. 
This paper includes specific questions to guide commenters. 

 

For More Information on Chloropicrin Health Effects:  

EPA-HQ-OPP-2007-0350-0005 – Chloropicrin Human Health Risk Assessment 

For More Information on Chloropicrin and Benefits:

EPA-HQ-OPP-2007-0350-0016 – Summary of the Benefits of Soil Fumigation
with Chloropicrin in Crop Production

For More Information on the Ecological Effects Associated with
Chloropicrin:

EPA-HQ-OPP-2007-0350-0013 – Phase IV Level I Screening Ecological Risk
Assessment for the Reregistration of Chloropicrin

For More Information on the Antimicrobial Uses of Chloropicrin:

EPA-HQ-OPP-2007-0350-0012 – Revised Occupational and
Residential/Bystander Assessment of the Antimicrobial Use (Remedial Wood
Treatment) of Chloropicrin

