1
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When
sodium
cyanide
is
used
as
a
fumigant,

hydrogen
cyanide
is
generated
by
acidification.

Because
residues
of
HCN
may
remain
on
fumigated
citrus,
the
Agency
is
conducting
an
acute
dietary
risk
assessment
of
hydrogen
cyanide.
2
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1.
Scientific
considerations:

The
Agency's
WOE
document
describes
a
lack
of
data
appropriate
for
developing
an
acute
dietary
risk
assessment
for
hydrogen
cyanide.
The
WOE
and
DER
present
the
results
from
a
clinical
trial
with
amygdalin
and
the
usefulness
of
this
clinical
trial
in
the
acute
dietary
risk
assessment
for
hydrogen
cyanide.
The
Agency
has
concluded
that
the
clinical
trial
is
appropriate
for
establishing
a
point
of
departure
in
the
acute
dietary
risk
assessment
for
hydrogen
cyanide.

Please
comment
on
the
scientific
evidence
that
supports
this
conclusion.
3
2.
Ethical
considerations:

In
its
ethics
review
of
this
research,
EPA
did
not
identify
any
deficiencies
with
respect
to
the
ethical
conduct
of
this
research.
The
Agency
asks
that
the
Board
provide
comment
on
the
following,
taking
into
account
all
that
is
known
about
the
ethical
conduct
of
this
study:


OPP's
conclusion
that
there
is
not
clear
and
convincing
evidence
that
the
conduct
of
the
research
was
fundamentally
unethical;
and

whether
there
is
clear
and
convincing
evidence
that
the
conduct
of
the
study
was
significantly
deficient
relative
to
the
ethical
standards
prevailing
when
the
study
was
conducted.

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