				

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES



April 19, 2007

MEMORANDUM

SUBJECT:	Response to Comments Concerning Chloropicrin Incident Report

		Phase III Comment Period for the Fumigant Chloropicrin

		DP Barcode DP314383

FROM:	Ruth Allen, Ph.D., MPH, Epidemiologist

		Chemistry and Exposure Branch

		Health Effects Division (7509P)

THRU:	David J. Miller, Branch Chief

		Chemistry and Exposure Branch

		Health Effects Division (7509P)

TO:		Nathan Mottl, Chemical Review Manager

		Kelly White Sherman, Team Leader

		Special Review and Reregistration Division (7508P)

BACKGROUND

During the Phase III comment period, EPA received three public comments
concerning the Health Effect Division’s (HED) August 2004 Human Health
Incident Report Memorandum (J. Blondell, DP Barcode D306838). 
Commenting entities included Osmose Utilities Services Inc.
(EPA-HQ-OPP-2006-661-0026[1]); the Chloropicrin Manufacturers Task Force
(EPA-HQ-OPP-2006-0661-0028); and, the California Rural Assistance
Foundation (EPA-HQ-OPP-2006-0661-0061[1]).  This memorandum reflects
HED’s response to these three public comments.

1. Comments from Osmose Utilities Services Inc.: HED appreciates the
additional information on Incident #5358-1; we will add the details
concerning additional mitigation practices implemented to the chemical
incident data file.  HED notes that this incident is from 1997 and the
incident was not life threatening.  Currently, HED is emphasizing
chloropicrin incidents which have taken place since 2000.  Of particular
regulatory importance are incidents which occurred in 2003 (O'Malley et
al., MMWR, 2004), in 2005 in California (Seqawa & Marade, CA Air
Dispersion Modeling Analysis of Priority Incidents, State of California,
2007) and,  2 incidents which occurred in Fall of 2006 in  San
Bernardino.

2. Comments from California Rural Assistance Foundation:  The Agency has
reviewed the MMWR 2004 chloropicrin article and updated the incident
data report with more current information.  The commenter is correct
that the CA surveillance system is not designed to report long-term
health effects.  HED confirmed the occurrence of the 2 incidents from
2006 in the state; the cases are being investigated by the California
DPR. This information is included in the Soil Fumigants Incidents
Summary Report.  

3. Comments from the Chloropicrin Manufacturers Task Force:  HED notes
the presentation by the Task Force included in the chloropicrin docket. 
The Task Force report terminates with 2003 incidents; additional
chloropicrin incidents have been reported in 2005 and 2006.  HED
believes that because adverse meteorological conditions are a recurring
problem and human settlement is in close proximity to treated fields,
the continuing pattern of poisoning incidents in the last 2 years
suggests that additional preventive intervention measures may be
warranted to reduce poisoning incidents.

	

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