UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

								OFFICE OF PREVENTION, PESTICIDES 

									AND TOXIC SUBSTANCES

				

MEMORANDUM						 27 March 2007                                          
           

						

SUBJECT:	Chloropicrin:  HED Response to Comments Submitted to the Agency
				Concerning the Product Chemistry Chapter for the Reregistration 			
Eligibility Decision [RED] Document, D268927 dated 10 October 2004.

		

		DP Barcode: D305341  

			Chloropicrin Docket ID Number:  EPA-HQ-OPP-2006-0661

			DP Barcode: D305330, PC Code: 081501

FROM:	P. Yvonne Barnes, Chemist

		Reregistration Branch II

Health Effects Division (7509P)

THROUGH:	Alan Nielsen, Branch Senior Scientist

		Reregistration Branch II

Health Effects Division (7509P), and

William Hazel, Chief

Reregistration Branch II

Health Effects Division (7509P)

			

TO:		Elissa Reaves and Charles Smith, Risk Assessors

		Reregistration Branch II

		Health Effects Division (7509P)

In the Federal Register of November 29, 2006 the EPA issued a notice
announcing the availability of EPA's human health and environmental fate
and effects risk assessments and related documents for the fumigant,
chloropicrin. Following closure of the comment period the primary
registrant (and data provider), Ashta Chemicals Incorporated, sent a
letter to the Agency with comments to the decision document. The
following memo is the Health Effects Division’s response to the Ashta
Chemicals Incorporated comments.  

Executive Summary

Chloropicrin [trichloronitromethane] is a non-selective soil and space
commodity fumigant used for the control of weeds, nematodes, insects,
rodents, and certain fungi. It is also a warning agent for use with
odorless fumigants, such as methyl bromide. Chloropicrin is a FIFRA
List-A reregistration chemical. The Chloropicrin Reregistration Standard
dated 12/07/1981 and Guidance Document dated 09/1982 required additional
generic and product-specific product chemistry data concerning
chloropicrin. 

A generic Data Call-In Notice (DCI) was issued 09/28/1990 to the
manufacturers of chloropicrin. Only the Great Lakes and Niklor technical
products were registered at the time of the Reregistration Standard. The
reregistration of chloropicrin is being supported by the Chloropicrin
Manufacturers’ Task Force (CMTF) including members Niklor Chemical
Company; Ashta Chemicals Incorporated; Trinity Manufacturing, Angus
Chemical Company; Great Lakes Chemical Corporation; Soil Chemical
Corporation Products; TRICAL; Arysta Life Science North America, and Dow
Agrosciences LLC.

Ashta Chemicals, Incorporated has responded to several product chemistry
deficiencies below:

1)  Ashta chemicals Comment 

UV/VISIBLE ABSORPTION STUDY

In the Risk Assessment EPA requested a UV/Visible absorption study.  EPA
had not previously requested this study for chloropicrin. However, the
CMTF has identified an existing recently completed study. The study will
be submitted shortly.

	

HED Response(s)

This is an Office of Pesticide Programs and Toxic Substances, OPPTS
830.7050, guideline data requirement for the technical grade of the
active ingredient [TGAI] or the pure active ingredient [PAI]. This study
must be submitted to the Agency.

2)  Ashta chemicals Comment 

OXIDIZING/REDUCion ACTION and VISCOSITY 

In the Risk Assessment EPA has asked from information from our company
on the Oxidizing Reduction and Viscosity.  For these two data
requirements our company will rely on a study previously submitted by
Niklor Chemical, MRID # 43434601.

HED Response(s)

HED concurs with Ashta Chemical’s reference to an acceptable study
such that no additional information is required.

3)  Ashta chemicals Comment

FLAMMABILITY/STORAGE STABILITY and CORROSION CHARACTERISTICS

In the Risk Assessment EPA has asked for information from our company on
Flammability, Storage Stability and Corrosion Characteristics. For these
data requirements our company will rely on a study previously submitted
by Niklor Chemical, MRID # 00013198.

HED Response(s)

HED concurs with Ashta Chemical’s reference to an acceptable study
such that no additional information is required.

4)  Ashta chemicals Comment

ENFORCEMENT ANALYTICAL METHOD

In the Risk Assessment EPA has asked for information from our company on
Enforcement Analytical Method. Additional information concerning the
Enforcement Analytical Method was provided to the Agency in a letter to
Walter I. Waldrop dated July 10, 1995. In the letter we discussed a lack
of a certified chloropicrin standard as explained earlier in this
letter.

HED Response(s)

HED concurs with Ashta Chemical’s reference to an acceptable
Enforcement Analytical Method such that no additional information is
required. A copy of the letter dated 10 July 1995 was attached to your
response letter dated 28 February 2007.

 

A sample of the chloropicrin used for characterization in MRID 43091402
must be submitted to the USEPA Laboratory.  

Samples should be sent to: Chief, EPA Analytical Laboratory,
Environmental Science Center, 701 Maples Road, Fort Meade, Maryland
20755-5350, Telephone Number: (410) 305 - 2931. Analytical standards
must be replenished as requested by the Repository.

5)  Ashta chemicals Comment 

	CERTIFIED CHLOROPICRIN REFERENCE STANDARD

For several of the studies EPA has a raised question because of a
certified chloropicrin reference was not used to generate the product
chemistry data.  

HED Response(s)

HED concurs with Ashta Chemicals that no additional information is
required pursuant to the analysis reported to EPA (MRID 43091402). 

Health Effects Division Recommendation(s)

The CMTF should consider sending a sample to the National Institute of
Standards and Technology (NIST) to become part of the National Reference
Standard Database if practical.

Health Effects Division Conclusion(s)

Provided that the registrant submits the data required and certifies
that the suppliers of beginning materials and the manufacturing
processes have not changed since the last comprehensive product
chemistry review or submits new complete updated product chemistry data
packages,  HED has no objections to the reregistration of chloropicrin
with respect to product chemistry data requirements.

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