	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	WASHINGTON, D.C.  20460

August 13, 2007

MEMORANDUM

SUBJECT:		Risk Assessment and Science Support Branch’s (RASSB’s)
Comments Concerning Chitosan Registration of Indoor Uses (128930)

FROM:		Norm Cook, Chief

Risk Assessment and Science Support Branch

Antimicrobials Division (7510P)

TO:			Adam Heyward, PM-34

Regulatory Management Branch II

Antimicrobials Division (7510P)

DP

BARCODE:	None

Pesticide

Chemical No.: 128930

Introduction

The Risk Assessment and Science Support Branch (RASSB) was requested by
staff from the Biopesticides and Pollution Prevention Division (BPPD) to
determine if an environmental assessment has been completed for chitosan
indoor uses registered by the Antimicrobials Division (AD) in prior
years.  RASSB checked branch and divisional files and was not able to
locate such an assessment.  However, based upon a review of the
available information we offer the following.

RASSB Conclusions/Comments

	It is our understanding that chitosan (poly-D-Glucosamine), under
Registration Number 81446-1, was registered by AD for various uses
including treatment of:  textiles, carpets, synthetic turf, laundry,
wallboard, etc.  The majority of chitosan uses appear to be indoor uses,
but obviously uses such as synthetic turf could be considered as an
outdoor use.  However, although RASSB did not perform an environmental
review for 81446-1, we note that chitosan is a naturally occurring
substance produced from chitin extracts of crustacean shells (e.g.,
crab, shrimp, and lobster).  Further, chitosan is used in numerous
applications involving ingestion through food and drugs, topical
application of drugs and cosmetics, intraperitoneal injections and nasal
inhalers.  Additionally, available information indicates that chitosan
is relatively nontoxic.

	Considering the above, RASSB concludes that environmental hazards and
exposures from use of the 81446-1 product should be minimal.  The
proposed use patterns, including synthetic turf (which is usually found
in enclosed stadiums), provide for minimal environmental exposure; and
the available information, which indicates relative nontoxicity, points
to minimal hazards for nontarget organisms.

	In closing, if there are any questions on the above, please contact
Norm Cook of RASSB.

cc:	N. Elkassabany, AD

	M. Hartman, AD

	D. Isbell, AD

	C. Pfeifer, BPPD

	R. Petrie, AD

	

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