1
MITC
Charge
to
the
HSRB
MITC
Charge
to
the
HSRB
MITC
is
an
irritating
compound
that
has
a
limited
animal
database
for
toxicity
via
inhalation,
the
key
route
of
exposure.
MITC
can
be
used
as
a
pesticide
directly
to
treat
wood
poles,
but
the
major
pathway
of
exposure
to
MITC
is
from
degradation
of
several
fumigant
pesticides
(
i.
e.,
metam
sodium,

metam
potassium,
and
dazomet).
Due
to
its
volatility,
MITC
has
the
potential
to
move
off­
site,

which
can
result
in
exposure
to
bystanders
near
treated
areas
and,
through
ambient
air,
to
people
far
away
from
treated
areas.
Use
of
the
soil
fumigants
also
results
in
exposure
to
those
handling
the
pesticides
or
working
in
treated
fields.
2
MITC
Charge
to
the
HSRB
MITC
Charge
to
the
HSRB
1.
Scientific
considerations
The
Agency's
WOE
document
and
DER
for
MITC
describe
the
study
design
and
results
of
the
MITC
odor
threshold
and
eye
irritation
human
studies.
The
WOE
document
also
discusses
the
Agency's
conclusions
that
the
eye
irritation
study
is
useful
for
the
assessment
of
potential
effects
on
bystanders
and
workers
from
exposures
to
MITC
during
acute
(
1­
day)
intervals.
3
MITC
Charge
to
the
HSRB
MITC
Charge
to
the
HSRB
1.
Scientific
considerations,
cont'd
The
Agency
has
concluded
that
the
odor
threshold
study
is
less
useful
than
the
eye
irritation
study
for
assessing
the
human
health
effects
of
MITC,
since
the
odor
detection
threshold
for
humans
is
higher
than
the
level
that
causes
eye
irritation.
The
Agency
has
decided,
however,
to
use
the
results
of
the
eye
irritation
study
for
assessing
the
inhalation
exposure
of
MITC.

Please
comment
on
the
scientific
evidence
that
supports
this
conclusion.
4
MITC
Charge
to
the
HSRB
MITC
Charge
to
the
HSRB
2.
Ethical
considerations
The
Agency
requests
that
the
Board
provide
comment
on
the
following:

a.
Is
there
clear
and
convincing
evidence
that
the
conduct
of
the
human
eye
irritation
study
with
MITC
was
fundamentally
unethical?

b.
Is
there
clear
and
convincing
evidence
that
the
conduct
of
this
study
was
significantly
deficient
relative
to
the
ethical
standards
prevailing
at
the
time
the
research
was
conducted?
