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CURRENT REPORT
testing should be tested for neurobehavioral toxicity, "ex
cept for those which have been demonstrated to be potent
carcinogens,''; According to the association committee,
"Commercial use of potent carcinogens will occur in situa
tions where human exposure would be prevented, hence no
neurotoxicity will occur."
/
The committee noted that the chemicals have "marked
potential for neurotoxic effects ana may offer an unreason
able risk of injury to health." More testing is needed to
characterize these effects, the group added.
E.I. du Pont de Nemours & Co. told the agency that the
firm is conducting a survey of phenylenediamine exposure
and release, claiming that the exposure data used by EPA to
consider the test rule are inaccurate.
All industry representatives/opposed use of either a sig
nificant new use rule under Section 5(a) or risk list designa
tion under Section 5(bX4) of TSCA. According to Dupont, use
of both "would have the incongruous result of requiring a
manufacturer or `new' user/to prove that a proposed use
would not present an unreasonable risk to health or the
environment."
Pesticides
EPA SEEKS COMMENTS' ON PROPOSAL TO ALLOW UNLABELED USES IN NURSERIES, GREENHOUSES
Commercial nursery And greenhouse operators would be
allowed to use pesticides in certain ways not specifically
permitted by labeling*, under a proposed Environmental
Protection Agency policy, which is the subject of an agency
request for public comments.
.
.
A notice requesting comments was signed May 6 by
Edwin L. Johnson, director of the agency's Office of Pesti
cide Programs. The hotice is expected to appear soon in the
Federal Register.. /;
.
The agency notice differs from an earlier draft (Current
Report, March 5i p. 1237) primarily in being more
noncommittal.- /
Where the earlier draft would have announced that the
agency "is proposing a policy," the final version simply
states that "EPA is considering whether to develop a deter
mination" on the issues.
'
: The "proposed /policy" and "other options" of the earlier
draft are lumped together as "options under consideration,"
in the final versibn. -
. Six Options
. According to; the notice, the agency is considering the
establishment of a new policy, under Section 2(ee) of the
Federal Insecticide, Fungicide, and Rodenticide Act Under
the.policy, the agency would declare that certain unlabeled
' uses do not violate the act.
. The agency [would permit commercial use of registered
pesticides under one or more of the following options:
. A pesticide labeled for use on nursery plants could be
used to contrjbl labeled pests on nursery crops other than
food/feed crops, as long as labeled application methods are
used.
I
A pesticide labeled for use on any greenhouse plants
could be used to control labeled pests on all greenhouse
crops, except food/feed crops, following labeled application
methods. I
A general-use pesticide labeled for food-crop use could
be used to control labeled pests on non-food/non-feed crops
in commeeIrrecial nurseries, following labeled application methods.
247
Any pesticide registered for food crops could be used to
control labeled pests oh non-food/non-feed nursery and
greenhouse crops, using any application method not prohib
ited by labeling.
j
.
Registrants of food-use products would be allowed to
amend registrations, without/submitting additional data or
incurring data compensation obligations, to permit use on
non-food/non-feed nursery/or greenhouse crops in accor
dance with labeled application methods. Registrants could
include label statements ^declaring that users are responsible
for any crop damage resulting from such use.
Pesticides registered for food uses could be used for non
food/non-feed nursery or greenhouse crops if the use is
given "third party certification" by a trade association,
extension service a gent, I or other specialist who would certi
fy that the use will not cause crop damage. Application
methods not prohibited by labeling could be used with third-
party endorsement i
None of the above options would allow indoor use of
products registered only for outdoor uses.
The notice provides for a 60-day comment period, follow
ing publication/in the Federal Register.
For further/information, contact Karen Flagstad, Policy
and Special projects Office (TS-766C), Office of Pesticide
Programs, EPA, Room 1109, Crystal Mall Bldg.- 2, 1921
Jefferson Davis Highway, Arlington, Va. 22202, (703) 557-
7102.
/
:i
/Polychlorinated Biphenyls
,, .
ADVERSE HEALT& EFFECTS NOT CERTAIN, SYMPOSIUM TOLD; MEETING CALLED BIASED
Recent studies on the health effects of polychlorinated
biphenyls raise questions about, the potential hazards of the
chemicals without giving very clear or consistent answers, a
May 12-13 health effects symposium was told.
About the only consistently reported adverse health ef
fects from PCBs are chloracne and enzyme induction, ac
cording to two speakers, William R. Gaffey, Monsanto Co.,
and consultant Seymour L. Friess, of Drill, Friess, Hays,
Loomis and Shaffer Inc. They said other studies reporting
more serious effects,! including cancer, gave conflicting
findings.
!
:
But other participants raised questions about the validity
of some of the studies that found few, conflicting, or no
adverse effects. Small study populations, inadequate follow
up, differences in exposure routes, and too small dosages
were suggested as possible factors affecting the study
results.
j
The two-day symposium, was sponsored by the Environ
mental Protection^ Agency to exchange scientific informa
tion on recent health and environmental exposure studies.
. ' Criticism Leveled
It was criticized byithe Natural Resources Defense Coun cil for having a pro-inclustry bias. NRDC attorney Jaqueline Warren May 4 wrote John Todhunter, assistant administra tor for pesticides and jtoxic substances, asking the agency to cancel the symposium.
Warren said most'of the people involved in panel discus sions at the symposium were either industry members or consultants, and claimed almost none of the speakers had first-hand knowledge of health effects from PCBs.
Warren said NRDC was informed that Todhunter had promised the Chemical Manufacturers Association the sym posium would be held "in time to coincide with (and presum-
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Chemical Regulation Reporter 1
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246
ably to influence) the agency's re-write of the PCB ban
reguations." Regulations previously excluding certain
chemical and electrical equipment from the PCB ban were
overturned by the U.S. Court of Appeals for the District of
Columbia Circuit in 1980, forcing EPA to re-write them
(Current Report, Oct. 31,1980, p. 986). .
. ..
Among recent data submitted to help EPA with its re
drafting were PCB studies by industry groups. They includ
ed health effects studies, one of which was done by the Drill,
Friess consulting firm. Another health effects reviewer who
worked for industry as part of the PCB data-gathering effort
also spoke at the symposium.
.
Todhunter wrote back to Warren May 10, saying that EPA
would not use the forum to renege on its agreement to draft
better PCB rules under the appeals court order. He also
encouraged the group to attend the conference, which it did,
and said the advance notice of the conference was distribut
ed widely to academic, government, industry, and profes
sional groups to encourage as much participation as
possible.
v
v; .
He offered to have an open discussion period added at the
end of the symposium during which additional "scientific
issues or questions" could be raised from the floor.
- The contract for the symposium specified that there was
[to be no discussion of the regulatory issues before EPA,
' according to Todhunter's office. Discussion leaders were
supposed to redirect any regulatory discussion back to the
scientific issues.
. .
..
`Mixed Bag' Of Results .
,
Gaffey told the symposium that his review of PCB epide
miological studies gave "no reason to believe there is a
carcinogenicity problem with PCBs" and "even less" evi
dence indicating problems other than chloracne and enzyme
induction.
.
Friess said a review of animal teratogenicity studies gave
"a real mixed bag" of results. He said three studies on
cancer by "major laboratories" gave different results.
. One of the problems widely discussed was the difficulty in
analyzing the 209 different PCB molecules known to exist.
This point was raised in CMA comments on the new rule
making. The association told EPA that detecting the mole
cules in chemical streams was an expensive proposition
because each one had to be created and printed so that its
individual pattern later could be identified if it appeared in
a chemical process (Sept. 4, 1981, p. 509).
...
. .
Toxicity Varies ...
V .
One of the speakers at the symposium, Stephen Safe,
Texas A&M University, reported work he had done creating
different PCB molecules and then measuring their ability to
induce a certain enzyme in laboratory tests. The induction
ability, he said, might indicate toxicity.- . .
" He explained that the degree of enzyme induction depend
ed on the position of chlorine atoms on the biphenyl mole
cules, which might explain why some PCBs or Arochlors
would give positive toxicity results and others negative
results.
He said he had identified four PCB molecules that showed
unusually high enzyme induction ability. Two of the four
were tetrachlorobiphenyls, one was a pentachlorobiphenyl,
and one a hexachlorobiphenyl.
Safe said tests were continuing on actual toxicity, but that
existing studies on toxicity generally confirmed that the
four he identified were toxic.
He said questions that remain to be answered include
whether PCBs are carcinogenic and what effects they give
CHEMICAL REGULATION REPORTER
at low levels. Safe said that the most active of his PCBs was
about four times less!active than dioxin.
.
;. .si&iaaror-
Reporting
.= ir.zr.rjr.:
*L-.
27 TSCA CHEMICAL INVENTORY LISTINGS
.
MAY BE REMOVED DUE TO ERRORS, NEW ANALYSIS
The Toxic Substances Control Act chemical inventory
would be 27 listings shorter under an Environmental Protec-,
tion Agency notice of jintent to remove the substances on the
basis that they were incorrectly reported.
According to a May 13 announcement (47 FR 20663), the
agency is seeking comments on plans to remove from the
inventory 27 listings that were the subjects of reporting,
typographical, or transcriptional errors. The mistakes also
may have stemmed [from chemical name changes due to
"improved analytical equipment and methods" of descrip
tion, the agency saidJ
-
EPA asked for information on whether any of the chemi
cals in the list have [been manufactured or imported since
the beginning of 1975, whether the chemicals, have been
correctly reported, or whether the chemicals should remain
on the inventory for any other reason.
.
Manufacture of any of the chemicals begun before the
notice was published may continue until. publication of a
final notice, according to the agency. However, the chemi
cals will not be retained on the inventory solely on the basis
of manufacture, importation, or processing. . " ..
The chemicals are:
.
.'
_
65086-37-5 Nonanoic acid, 2,2-dimethyl-, oxiranyl-
methyl ester, polymer with ethenylbenzene, 2-hydroxyethyl
2-propenoate, 1,3-isobenzofurandione and methyl 2-methyl-
2-propenoate.
i
" . ..
65121-76-8 Phenol, 2-methyl-4,6-dinitro-, lead (2+) salt.
65122-05-6 Diazene, [(l,3-dihydro-l,l,3-trimethyl-2H-
iden-2-ylidene)methylX2-methoxyphenyl)-. .
65151-55-5 Docosanoic acid, l,3,5,-triazine-2,4,6-triyl-
tris[(methoxymethyl)imino]methylene ester. . .
65530-81-6 Poly(difluoromethylene), a-(2,2-dichloro-
l,l,2-trifiuoroethyl)-W-hydro-.
' ;
65717-13-7 4-Primidinecarboxylic acid, 1,2,3,6-tetrahy-
dro-5-nitro-2,6-dioxor, monopotassium salt . .'. " .
67892-76-6 Nonanoic acid, 2,2,-dimethyl-,, oxiranyl-
methyl ester, polymer with butyl 2-propenoate, methyl 2-
methyl-2-propenoate and 2-propenoic acid. . '
67892-78-8 Nonanoic acid, 2,2-dimethyl-, oxiranylmethyl
ester, polymer withj butyl 2-propenoate, ethenylbenzene, 2-
hydroxyethyl 2-propenoate and 2-propenoic acid.
68110-21-4 Zincate(l-), trichloro-, hydrogen, compd.
with N,N-d|ethyl-4-{(l-inethyi-lH-l,2,4-triazol-5-yl)azo] ben-
zenamine (1:1).' ' *'-N! >
1: . -
68213-43-4 Fatty acids, tail-oil, polymers with bisphenol
A, bisphenol A diglycidyl ether, Bu acrylate, 2-(dimethyl)a-
mino)ethyl methacrylate, 2-{(l, 1-dimethyl) .aminojethyl mel-
hacrylate, glycidyl| 2,2-dimethylnonanoate, hydroxyethyl
methacrvlate and Me methacrylate. . . . .
71002-23-8 l.l'-Bi-lH-imidazole, ! 2,2',5,5ttetrakis(2-
chlorophenyl)-4,4',bis(3,4-dimethoxyphenyl)-. - '
. 7^735-70-1 B-Alanine, N-{3-(nonyloxy)propyl]-. :
71799-76-3 9,11-Octadecadienoic acid, (Z,Z)-, polymer
with 2-hydroxyethyl 2-methyl-2-propenoate, methyl 2-meth-
yl-2-propenoate, (Z,Z)-9,12-octadecadienoic acid and oxiran
ylmethyl 2,2-dimethlylnononoate.
....
74398-77-9- Benzenediazonium, 2-methoxy-5-methyl-4-
[(3-sulfophenyl)azo}-', chloridej ... ~. ' ' '
74642-98-1 Cuprate(2-),[bis(aminosulfonyl)-29H,31H-
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Copyright O 1082 by The Bureau of National Affairs, Inc. 0148-7873/82/J00.50
PCB-ARCH-EXT0378580