 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

MEMORANDUM

Date:	October 23, 2008

SUBJECT:	Coumaphos. Response to comments from USDA/APHIS on the PWP for
coumaphos.  

PC Code:  036501	DP Barcode:  347384

MRID No.:  Not Applicable 	Registration No.: Not Applicable

Petition No.:  Not Applicable	Regulatory Action: Not Applicable

Assessment Type:  Not Applicable	Reregistration Case No.:  Not
Applicable

TXR No.:  Not Applicable

	

FROM:	Shanna Recore, Risk Assessor

	Donald Wilbur, Chemist

		Health Effects Division (7509P)

		Office of Pesticide Programs

THRU:	Felecia Fort, Branch Chief

		Health Effects Division (7509P)

		Office of Pesticide Programs

TO:	Wilhelmena Livingston, Chemical Review Manager

	SRB Branch

Special Review and Reregistration Division (7508P)

		Office of Pesticide Programs

Executive Summary

Attached is the Health Effects Division (HED) response to comments from
the United States Department of Agriculture, Animal and Plant Health
Inspection Service (USDA APHIS). HED appreciates the comments submitted
by USDA APHIS regarding the Agency’s coumaphos Registration Review
summary document.  USDA APHIS provided comments pertaining to Ecological
and Human Health Risk.  HED has reviewed the comments specific to human
health risk and will consider these comments as the registration review
process is carried forward.  



APHIS’s Comment: The 2002 PDP monitoring data for beef indicated that
there was no

detection of coumaphos in the 301 samples taken of beef adipose, 313
samples of beef

liver, and the 310 samples of beef muscle. (See attachment 1 for
relevant page(s) or see

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=PDP2002Summary for full

report.) While the CFTEP does not treat and has no need to treat swine,
APHIS also

wishes to point out that coumaphos residues have not been detected in
pork tissue. (See

attachment 2 for relevant page(s) or

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5049946 for
full

report.)

HED’s Response:  The Agency is required by FQPA to revisit the data
five years after the tolerance assessment decision; therefore, the
Agency will need to revisit the United States Department of
Agriculture’s (USDA) Pesticide Data Program (PDP) monitoring data for
beef and milk that were used in the previous dietary risk assessment. 
HED appreciates the comments submitted by USDA APHIS and will consider
these comments when the next risk assessment is performed for coumaphos.
 

APHIS’s Comment: APHIS agrees that the occupational risks for the
CFTEP have been

mitigated below EPA’s level of concern. APHIS would like to provide
data to further

support this determination. In 2002 and 2005, the National Institute for
Occupational

Safety and Health (NIOSH) investigated the cholinesterase monitoring
program for

animal health technicians in the CFTEP. One of the study’s findings
was that none of

the technicians had plasma cholinesterase or acetylcholinesterase levels
outside the

laboratory’s range of normal. Chlorferon was detected in the urine of
all animal health

technicians after they used coumaphos, however levels were significantly
lower the day

following exposure. (See attachment 3 for a full copy of the study.)
While the study was

critical of the program’s use of PPE, current PPE has been improved,
and the negative

findings in the program were corrected. Applicators undergo 5 hours of
pesticide

training every year: 2 hours of mandatory training required by the State
of Texas and

3 hours of mandatory in-house training specific to coumaphos dipping
with the CFTEP.

This training includes management of dipping vats, pesticide
application, and safety.

Additionally, cholinesterase testing is performed every 60 days on
animal health

technicians that apply coumaphos in the CFTEP.

HED’s Response:  HED has received the NIOSH Health Hazard Evaluation
Report (HETA#2002-0203-3050).  No additional data is needed for the
coumaphos risk assessment at this time. HED does not anticipate using
this study in a coumphos risk assessment; however, if we decide to use
it, the study will need to undergo an internal ethics review.

 PAGE   

Page   PAGE  1  of   NUMPAGES  2 

