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Nuarimol (DowElanco). 1992 Greenpeace Report: "Never-Registered Pesticide."
FAN note:
Two of the "never-registered" pesticides discussed in this Greenpeace report are fluorinated: Haloxyfop and Nuarimol. Both are produced by DowElanco.http://www.greenpeace.org/gopher/campaigns/toxics/1992/neverreg.txt
NEVER-REGISTERED PESTICIDES: Rejected Toxics Join the "Circle of Poison"
Greenpeace USA Pesticide Campaign (Sandra Marquardt)
February 1992
Five Case Studies of Pesticides Manufactured by:
DowElanco
FMC Corporation
Mobay Corporation
Monsanto Agricultural Company
By Sandra Marquardt, Laura Glassman and Elizabeth Sheldon
Research Assistance: Tom Plant
Cover Design by Kevin Cross, Free Hand Press Copyright Greenpeace U.S.A., Inc. 1992
July, 1990 - first edition
February, 1992 - second edition
Greenpeace
1436 U St., NW Washington, DC 20009 (202) 462-1177
Printed on unbleached 100% post-consumer waste recycled paper.
TABLE OF CONTENTS
I. Introduction ................................ 1
II. Background Summary ........................ 2
III. Findings
A. Registrations Rejected . ............ 3
B. Tolerance Rejected .................. 3
C. Illegal Pesticide Residues on Imported Food ........................................ 4
D. Overview of International Use of Never- Registered Pesticides .... ........ 5
E. Export Notification Provisions Flawed ........................................ 6
F. Data on Toxicity/Environmental Fate Kept Secret ........................................ 6
IV. Conclusion .................................. 8
V. Case Studies
Butachlor by Monsanto ................ 10
Carbosulfan by FMC .................... 16
Haloxyfop by DowElanco ... ............ 22
Nuarimol by DowElanco .. .............. 28
Prothiophos by Mobay .................. 33
I. INTRODUCTION
Every year, about 100-150 million pounds of pesticides that cannot be used in the United States are exported for use overseas. This amounts to approximately one-quarter of the annual U.S. pesticide export market. (9)
Some of the exported pesticides actually have been rejected from domestic use or consumption yet U.S. law permits their export for use overseas. Once there, they are used on such widely consumed fruits and vegetables as apples, pears, carrots, and pineapples, as well as on crops grown for wine and beer.
The production and transportation of these pesticides, their use overseas and consumption of residues contribute to what is known as the "Circle of Poison."
Never-Registered Pesticides: Rejected Toxics Join the "Circle of Poison" contains case studies of five never-registered pesticides exported by U.S. pesticide industry giants DowElanco, FMC Corporation, Monsanto Agricultural Company and Mobay Corporation. The pesticides are: butachlor, carbosulfan, haloxyfop, nuarimol, and prothiophos.
The case studies demonstrate that, contrary to the industry claims of safety, all five products have actually had their registration application and/or tolerance petitions rejected by the Environmental Protection Agency (EPA), the federal agency which regulates pesticides, because of health or environmental concerns. Thus, Greenpeace believes that the never-registered pesticides should be considered just as dangerous as banned pesticides.
Industry also claims that certain never-registered pesticides are intended for use solely on crops overseas that are not grown in the U.S. This study shows, however, that all five pesticides are used on a variety of crops, including those grown in the U.S., as well as those intended for U.S. consumption. Industry has not named one never-registered pesticide to support its statement.
The export of never-registered pesticides cannot be justified by industry and should not be condoned by Congress. Greenpeace believes that the export of such products should be prohibited and that the loopholes which allow a double standard between domestic and export pesticide regulation need to be closed through immediate statutory change.
II. BACKGROUND SUMMARY
Section 17 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) permits the export of never-registered pesticides, even when EPA has rejected or not yet approved registration applications because of health and/or environmental concerns.
FIFRA also permits the export of never-registered pesticides for food use, even if EPA rejects a manufacturer's petition for a food tolerance. Food tolerances establish permissible amounts of pesticide residues on food.
All that FIFRA requires is that manufacturers register their production facility with EPA, submit the necessary data if they desire domestic registration and give notice of the export of unregistered (banned or never-registered) pesticides to the foreign purchaser. EPA is to pass on the information to the importing government (see "Notification"). The export notices must state that the product is not registered for use in the United States, wording which also must be on the label.
All production facilities are registered with EPA. However, NONE of the five pesticides which have been subject to one or both types of regulatory review has passed that review. Indeed, the Agency has rejected tolerance petitions for all five pesticides as well as the registration applications for those three pesticides for which manufacturers applied for domestic use: butachlor, carbosulfan and haloxyfop. EPA denied the registrations because of concern that the pesticides may cause cancer, birth defects, residue problems, or harm to fish and wildlife. (See following case studies.)
The export notification program is faulty as well. No information on the potential toxicity or environmental fate of the product must be contained within the notice, shipment may proceed to the country before the government has received the notice, and EPA sends the notice to the U.S. embassy in the importing country for forwarding, although there are no formal procedures governing their processing and transmittal. (9)
The practice of exporting never-registered persticides is not without its serious implications.
The production of the pesticides results in the environmental discharge of manufacturing wastes, as well as exposure to manufacturing workers and the community surrounding the production plant. Then, the pesticides are transported several thousand miles, on main highways and railways, to ports on every coast - mostly to Oakland and Los Angeles, CA; New Orleans, LA; and Tacoma, WA.
Once overseas, they often are used by workers who are inadequately trained, cannot read the label, or lack protective clothing or do not use it because of the discomfort in the heat and humidity and the expense. In the absence of protection, farmworkers and their families are exposed to pesticides which are too hazardous for use in the U.S.
Consumers then eat imported foods treated with these pesticides. Border control efforts provide little protection since the Food and Drug Administration (FDA), which is in charge of testing fruits and vegetables, samples only 1-2 percent of incoming shipments. (8) The Department of Agriculture (USDA), which is responsible for testing meats, poultry and eggs, has a policy not to test for any pesticide which is not part of its domestic testing program, thus automatically excluding the never-registered pesticides! (11)
From production to use and subsequent consumption, few controls are in place to protect public and environmental health. Below, we explore particular examples demonstrating this.
III. FINDINGS AND DISCUSSION
A. Registration Applications Rejected
To be allowed for use domestically, pesticides are subjected to a series of tests prior to registration. Manufacturers must conduct these studies on the short- and long-term toxicity and environmental fate. EPA then reviews them to determine the pesticide's potential effects on health and the environment.
Pesticides which fail these testing requirements are denied registration by EPA, and cannot be used domestically. However, they can still can be exported for use overseas.
Manufacturers of three of the five never-registered pesticides reviewed, DowElanco (haloxyfop-methyl), FMC (carbosulfan) and Monsanto (butachlor), have applied for domestic registrations for their pesticides. All applications were rejected by EPA because of the Agency's concerns over the chemicals' ability to cause cancer and other harmful health and environmental effects. (See following case studies.)
B. Residue Tolerance Applications Rejected
If manufacturers have reason to suspect that residues of their pesticides will remain on treated foods, they may petition EPA for a food residue tolerance, or a permissible amount of residue on a commodity. This is because if the pesticide has no tolerance, any residue of that pesticide is considered illegal and the commodity is subject to seizure at the border.
To apply for a tolerance, a company must submit numerous toxicology and residue chemistry test results to EPA for review. However, in the assessment of dietary risks, problems of worker exposure or environmental harm are not considered.
All four manufacturers studied have reason to believe that residues of their never-registered pesticides will remain on treated crops, and all four have petitioned EPA for tolerances. Interestingly, they have not applied for tolerances for all crops on which their products are used.
EPA has rejected the food tolerance petitions for all five pesticides, due to concern that they may cause cancer, birth defects and other long-term health problems. Nonetheless, all five pesticides are exported for use on food and beverage crops, including crops which the U.S. regularly imports. Only one of the five, carbosulfan, has a food residue limit established in the United Nations' Codex Alimentarius list of standards used internationally. However, even carbosulfan's Codex standard is only established for citrus, not any other of the numerous crops the pesticide is used on. (2)
C. Illegal Pesticide Residues on Imported Food
The absence of food tolerances does not mean that illegal pesticide residues will not end up on our food. Indeed, imported food is rarely tested for illegal residues at the border. The agencies in charge of border testing, FDA and USDA, lack both the staff and residue test methods necessary to have an adequate testing program.
For example, FDA only tests 1-2 percent of imported food shipments. Even then, it can test for less than half of the active ingredients registered for use. (7,8) It currently has no operating test method for one of the never-registered pesticides--haloxyfop (either -ethoxyethyl -methyl) in this review. (7) Providing a strong indication that exported never-registered pesticides circle back as residues in imported foods is the fact that Mobay's insecticide prothiophos has been detected in several commodities over the last decade. In fact, since 1982, FDA has detected prothiophos on 12 samples of imported produce including: three samples of berries from South Africa, three samples of pears from Japan, one sample of mustard greens from Thailand and five samples of pickles from Sri Lanka. (6) The U.S. levels detected are in violation of the tolerance levels in four countries for prothiophos on similar commodities. (1)
As mentioned above, USDA's testing program does not test for never-registered pesticides as a matter of policy. (11) The Agency only tests for those pesticides which are part of its domestic testing program. Even if the policy did not exist, USDA does not have a test method for haloxyfop. (12) This is despite the concerns of the manufacturer, DowElanco, that residues may return on imported meats, as demonstrated by the company's 1985 food tolerance application for haloxyfop in meats and poultry. (3)
The lax border testing by these agencies virtually assures that residues of the never-registered pesticides will pass through the border to the consumer undetected, thus completing the "Circle of Poison."
D. Overview of International Use of Never-Registered Pesticides The following U.S.-exported never-registered pesticides are used widely on food crops potentially imported into the U.S. (See case studies for references.) Greenpeace research shows:
* Monsanto's herbicide butachlor is used on rice in Thailand, the number 1 exporter of rice to the U.S., as well as in several other rice exporting countries. EPA rejected Monsanto's tolerance and registration efforts due to "residue, environmental, fish and wildlife, and toxicological" concerns.
* FMC's broad-spectrum insecticide carbosulfan is used on rice fields in Thailand, the number 1 exporter of rice to the U.S. It also is used on a variety of vegetables and sugarbeets in several countries. Since 1982, FMC has submitted nine registration applications and five tolerance petitions for use of carbosulfan on citrus fruits, alfalfa, sorghum, apples, and pears. To date, EPA has refused to grant any of the petitions, stating that there are too many deficiencies in the data. EPA is particularly concerned about the effects of carbosulfan relating to potential groundwater contamination.
* DowElanco's systemic herbicide haloxyfop-methyl is used on soy in Australia, Argentina and Costa Rica, the numbers 1, 4 and 5 exporters, respectively, of beef and veal to the U.S. (soy is fed to the animals); grapevines in France, the number 2 exporter of wine to the U.S.; and oil palms in Indonesia, the number 2 exporter of palm oil to the U.S. EPA rejected both tolerance and registration efforts due to concerns the chemical is a "probable human carcinogen."
* DowElanco's fungicide nuarimol is applied to barley seed in Germany and the United Kingdom, the number 4 and 5 exporters, respectively, of malt beverages to the U.S. Nuarimol is also used on grapevines in Italy, France and Spain, which are, respectively, the number 1, 2 and 3 exporters of wine to the U.S. EPA rejected the nuarimol tolerance application due to concerns over the chemical's potential to cause cancer and birth defects.
* Mobay's insecticide prothiophos is used on apple orchards in New Zealand, the number 3 exporter of apples to the U.S. It also is used on tea in Indonesia, the number 3 exporter of tea to the U.S.; and on pears in Japan, the number 4 exporter of pears to the U.S. EPA rejected Mobay's tolerance petition due to concerns raised over data submitted to the Agency in support of the petition. Studies submitted in 1989 to EPA demonstrate that prothiophos causes birth defects in laboratory rats and rabbits.
E. Export Notification Process Flawed
The United States is the only country in the world to require that pesticide exporters notify overseas importers of the shipment of an unregistered pesticide (banned or never- registered). The process is intended to provide useful information to both the purchaser and foreign government about the lack of U.S. registration status, information upon which a government can make educated decisions concerning risk.
Section 17(a) of FIFRA requires that before such pesticide can be exported, the exporter must provide notification to the foreign purchaser prior to the first shipment of the year. The notice must state that the pesticide "...is not registered for use in the United States and cannot be sold in the United States." (5) The purchaser must acknowledge the notification, stating that the lack of U.S. registration is understood.
The exporter then must forward the acknowledgement to EPA along with certification that export did not take place prior to notification. EPA sends copies of the statements to U.S. embassies in the importing countries. The embassies are to forward the statements to the appropriate official in that country's government. (5,9)
This program, while well-intended as a useful information tool, is severely flawed. Often the foreign purchaser is a subsidiary of the exporting company, thus making notification an exercise in paper transmission. Furthermore, no information on the toxicity or environmental fate of the pesticide must be included in any of the notices, there are no formal procedures for the embassies to follow in forwarding the documents so the documents may never be forwarded to the correct contact and it is not required that the country official has received the notification before the product is shipped. (9)
F. Data on Toxicity/Environmental Fate Kept Secret
Lack of access to critical health and environmental information hampers the public's knowledge and understanding of risks posed by these products. Confidentiality restrictions in the U.S. and abroad result in a situation where no one besides the officials immediately involved with a registration scheme can determine potential risks.
In the U.S., data submitted to EPA to support registration are considered "trade secrets" under Section 10 of FIFRA. This section permits EPA only to release data for "registered or previously registered" pesticides, thus keeping secret the data on those pesticides which have not yet had their applications formally approved or denied. (4)
However, as demonstrated in most every case, registrations are rarely, if ever, denied and thus the data remains confidential for an indefinite period of time. "Confidentiality" plagues information exchange in other countries as well. Even in "developed" countries which have registered these pesticides, such as in European countries and in Australia and New Zealand, governments often do not have basic fact sheets on the health and environmental effects of their pesticides. (10) The scientific data provided the governments for registration purposes is not easily accessible to the public due to confidentiality laws protecting industry's data.
Thus, a non-regulator researching the potential human and environmental impacts of these pesticides must turn to the manufacturer for data. Not only is there an inherent conflict of interest in this case since it is not in the manufacturer's best public interest to disclose information demonstrating potentially harmful effects, but the information released may be incomplete or inadequate.
For example, the information manufacturers provide most readily for their products are "Material Safety Data Sheets" (MSDS). In the U.S., an MSDS is required under the Hazard Communication Standard of the Occupational Safety and Health Administration (OSHA). This overview document provides basic information on the potential threat to workers from exposure to the product.
However, MSDS's are limited to exposure risks to workers and often do not include environmental fate data. Nor do all manufacturers include in the MSDS the name(s) of the "inert ingredients," or carrying agents. This is despite the fact that the inert ingredients can be as toxic as, or even more toxic than, the pesticide they accompany. While information is confidential in some cases, it is misleading in others. For example, the United Nations' World Health Organization (WHO) has an international pesticide hazard ranking system, but it is based primarily on acute oral and dermal toxicity of the material to laboratory rats, not chronic effects. (13)
This means that a pesticide like butachlor, which can cause tumors, is listed as a "product unlikely to present acute hazard in normal use" and is not included in any "Class" at all. Similarly, haloxyfop, which EPA considers a "probable human carcinogen," is given a "Class II" or "moderately hazardous" ranking by WHO since it is not highly acutely toxic. (13)
IV. CONCLUSION The federal law governing "for export only" never-registered pesticides, FIFRA, does not adequately protect humans and the environment from exposure to potentially dangerous never- registered pesticides, whether in the U.S. or abroad. Rather, FIFRA's export loophole results in the exposure of citizens around the world to pesticides that have been rejected by EPA as too dangerous for domestic use or on food intended for the U.S. market. FIFRA also limits access to important human and environmental effect data critical to making educated assessments of potential threats.
Greenpeace believes that the legal loophole which allows the export of never-registered pesticides must be closed and the confidentiality clauses which keep important information secret must be opened. Congress has a responsibility to protect people and the environment, both here and abroad, from the hazards of never-registered pesticides, and should take immediate action to close the export loophole and end the "Circle of Poison."
INFORMATION SOURCES
BACKGROUND SUMMARY:
1. Canadian Bureau of Chemical Safety. "National Pesticide Residue Limits in Foods." Ottawa, Ontario, Canada, May 1990.
2. Codex Alimentarius Commission, United Nations Food and Agriculture Organization and World Health Organization Joint Committee. "Guide to Codex Maximum Limits for Pesticide Residues." Part 2, the Netherlands, April 1990.
3. Environmental Protection Agency (EPA). "Applications to Register Pesticide Products." 50 Federal Register (18 September 1985):37903.
4. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), Section 10 (7 U.S.C. sec. 136h).
5. FIFRA, Section 17 (U.S.C. sec 1360).
6. Food and Drug Administration (FDA), Division of Regulatory Guidance. "Listing of Pesticides, Industrial Chemicals, and Metals Data by Fiscal Year, Origin, Sample Flag, and Industry/Product Code," 21 August 1991.
7. FDA. "Statement for the Record: Committee on Agriculture, Nutrition and Forestry, U.S. Senate." 20 September 1991.
8. General Accounting Office (GAO). "Pesticides; Better Sampling and Enforcement Needed on Imported Food." GAO/RCED-86-219, Washington, DC:GPO,1986.
9. GAO. "Pesticides: Export of Unregistered Pesticides Is Not Adequately Monitored by EPA." GAO/RCED-89-128, Washington, DC:GPO, 1989.
10. Marquardt, Sandra. "Australia and Asia Trip Report" (internal Greenpeace report). January 1991: Communications with Greenpeace offices in Australia, Belgium, France, Germany, Italy, Netherlands and New Zealand, Pesticides Trust, UK, 1991 & 1992.
11. United States Department of Agriculture (USDA). Freedom of Information Act (FOIA) Response to Sandra Marquardt, 30 June 1989.
12. USDA. FOIA Response to Sandra Marquardt, 12 September 1991.
13. World Health Organization (WHO). "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990-1991." Geneva, Switzerland, 1991.
CASE STUDIES OF FIVE NEVER-REGISTERED PESTICIDES
Greenpeace has reviewed the registration status, international use, and health and environmental hazards for five pesticides that are made in the United States, but never have been regis- tered domestically or gained a food residue tolerance. The pesticides are: butachlor, carbosulfan, haloxyfop (- ethoxyethyl and -methyl), nuarimol and prothiophos. These never-registered pesticides are used overseas for a variety of uses, including food and beverage crops widely consumed in the U.S. Below is an overview of these five never-registered pesticides and the role they play in the "Circle of Poison."
1. BUTACHLOR: By Monsanto, Iowa
A. Registration Background
Butachlor is an acetamide compound used as a preemergence and preplant selective herbicide which is produced by Monsanto in Muscatine, Iowa. Butachlor is sold overseas under the trade names "Machete" and "Lambast". (24,36,44) Its chemical name is N-(butoxymethyl)-2-chloro-2',6'-diethylacetanilide. (27)
Monsanto's efforts to gain registration and residue tolerances for butachlor began in 1976 with an application for a food residue tolerance on rice. (13) This was followed by a feed additive petition in 1977, also for rice. (14) Several temporary tolerances and Experimental Use Permits (EUP's) were granted, all of which expired by the end of 1986. (15,41) In 1978, Monsanto applied for registration of butachlor on rice, but the application was rejected by EPA in 1984 due to several "environmental, residue, fish and wildlife, and toxicological concerns." (12,41)
It was also determined at this time that many of the long-term health studies regarding butachlor's capacity to cause birth defects, tumors, genetic damage and reproductive toxicity submitted to EPA by Monsanto (to support its applications) were invalid. (10) These tests were conducted by Industrial Biotest Labs (IBT) which halted testing in 1978 and whose scientists were later indicted for falsifying the results of animal tests. (40) In the fall of 1991, Monsanto withdrew all pending applications, which included the application for registration, and submitted a petition for an import tolerance. (42)
B. Health and Environmental Hazards
Health:
Exposure to butachlor poses both acute and chronic risks. Acute effects include skin and eye irritation and effects on the kidney, gallbladder and lungs. Chronic effects in rats and mice include decreased body weights, organ weight changes (liver and kidney), reduced brain size, cell damage (neoplastic and histopathological lesions) and tumors. (26) One Monsanto study showed the formation of tumors of the stomach, nose, thyroid and possibly kidney. (27)
Because national and international institutions focus primarily on the acute effects of pesticides when classifying potential human toxicity, they often oveerlook the long-term chronic effects, such as those outlined above. For example, butachlor falls under EPA equivalent of Class III, requiring only a `caution' warning statement on the label.(26) The World Health Organization (WHO) does not even give butachlor a classification among its list of hazardous pesticides, instead listing it as a product "unlikely to present acute hazard in normal use." (50) In the Philippines, butachlor bottles have a green band, the international indicator of a pesticide with low acute toxicity, thus not giving users notice of the potential long-term threat. (23)
An additional problem with pesticide toxicity evaluations is that some butachlor-based "Machete" formulations include inert ingredients such as xylenes and N-butyl alcohol. (26,28) Both of these chemicals can damage the liver and kidneys. Repeated exposure to xylenes can cause poor memory, concentration, and hearing and also affects the brain. They also can damage bone marrow and developing fetuses and cause low blood cell count. (30) N-butyl alcohol also damages the hearing and sense of balance. (31)
Environment:
Butachlor poses a threat to both ground and surface water supplies. For example, EPA reports that butachlor has the potential to leach into the groundwater. (16) Regarding surface water, application of butachlor is restricted in Hokkaido, Japan during the rice-planting season because the herbicide "flows out with the effluent water...causing contamination of river water and benthic animals". (32)
In Iowa, Monsanto is normally permitted to discharge over 394 pounds per year (1.08 pounds per day) of butachlor into the Mississippi River under the Clean Water Act. (19) However, in 1989 the plant was given an Administrative Order to upgrade its treatment facilities. While under construction Monsanto operates under an Interim Permit in which there are no discharge limits for butachlor. (20) Interestingly, since 1989 the plant has been discharging up to seven times the previous permitted maximum amount. (21)
Butachlor is highly toxic to fish, especially rainbow trout, bluegill, carp and channel catfish. Exposure of fathead minnow eggs to butachlor produced a decrease in the mean length and width of the minnows. Increased mortality and/or decreased body length and reproductive success was found in daphnia magna (freshwater crustacea) exposed to mid-and high levels of the product. (26)
In addition, butachlor can persist in the soil up to ten weeks. (38,44)
C. Advertising
Advertisements promoting the use of butachlor in the Philippines contained no warning symbols or phrases. Users, many of whom are illiterate, were advised to read the label for use precautions. (23,36) Monsanto's containers sold in the Philippines provided no protective clothing statements. Furthermore, the label warning to "avoid skin contact and inhalation of spray mist" is routinely ignored as workers mix the concentrate for backpacksprayers without gloves and walk barelegged into the spray they apply to the rice paddies for hours. (23) EPA does not have a copy of the export label since it is not EPA policy to keep a file of export labels for unregistered products. (11)
D. International Use
Butachlor is used overseas primarily in paddy rice, but is also used on corn, cowpeas, mungbeans, onions, sorghum and soybeans. (2,4,24,37)
Butachlor is used in Africa (1), Argentina (3), Brazil (5,25), China (2,4,25), Colombia (5,6,7,25,30), Costa Rica (8,48), Ecuador (9), Honduras (18), India (2,4,17,25), Indonesia (2,25), Japan (22,25), Nepal (2,25), Pakistan (2,25), Panama (33,49), Paraguay (34), Peru (35), the Philippines (2,25,37), Republic of Korea (2,4,25), Spain (39,47), Singapore (2), Sri Lanka (2,26), Taiwan (25), Thailand (2,25,43), Uruguay (45) and Venezuela (25).
One primary food item the U.S. imports from countries using butachlor is rice.
Butachlor is used on rice in Thailand, the #1 exporter of rice to the U.S. (5,25,43,46)
U.S. imports in 1987: 72,587 metric tons= 83.8% U.S. imports in 1988: 92,771 metric tons= 86.8% U.S. imports
in 1989:107,757 metric tons= 88.5% U.S. imports
in 1990:131,380 metric tons= 89.9% U.S. imports
Jan.-Nov. 1991:129,796 metric tons= 88.5% U.S. imports
Butachlor also is used throughout Africa, as well as in Argentina, Brazil, China, India, Taiwan, Thailand and Venezuela. Together these countries provide 97.5% of all rice imported to the United States. (46)
INFORMATION SOURCES
BUTACHLOR:
1. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Africa." Vol 3, Bangkok, Thailand, 1989.
2. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Asia." Vol 1 (1991 edition), Bangkok, Thailand, 1990.
3. Argentina. "Guia de Productos Fitosanitarios Para la Republica Argentina," 1988.
4. Asian Development Bank. "Handbook on the Use of Pesticides in the Asia-Pacific Region." Manila, Philippines, 1987 (November):133.
5. Battelle Europe. "World Pesticide Programme -- Herbicides II." Geneva, Switzerland, 1985.
6. Colombia, Ministerio de Salud Seccion de Toxicologia. "Manual de Informacion Toxicologica: Serie A." Bogota, Colombia, 1988.
7. Colombia, Instituto Colombiano Agropecuario. "Importacion, Produccion y Ventas de Plaguicidas de Uso Agricola," 1988.
8. Costa Rica. "Ministry of Agriculture Pesticide Registration List," 1989.
9. Ecuador, Ministerio de Agricultura Y Ganaderia. "Movimiento Estadistico de Pesticidas de 1989."
10. EPA. "Butachlor: Tox-1 Liner." Washington, DC: 4 April 1988.
11. EPA. Freedom of Information Act (FOIA) Response to Sandra Marquardt. 1 September 1988.
12. EPA. Correspondence with Senate Agriculture Committee, 1989.
13. EPA. "Food Additive Petition." 41 Federal Register (20 August 1976):35216.
14. EPA. "Tolerances for Pesticides in Animal Feeds." 42 Federal Register (8 April 1977):18620.
15. EPA. "Issuance of Experimental Use Permits." 49 Federal Register (8 August 1984):31757.
16. EPA. "Pesticides included in the EPA National Pesticide Survey." Washington: 14 April 1988 and EPA. "National Survey of Pesticides in Drinking Water Wells: Phase I Report." Washington, DC: November 1990.
17. Dudani, A.T., Dr., and Sanjoy Sengupta. "Status of Banned and Bannable Pesticides." Voluntary Health Association of India, India, (1991):15.
18. Honduras, Ministry of Agriculture. "Pesticide Registration List," 1989.
19. Iowa Department of Natural Resource, Des Moines, Iowa. "NPDES Permit No. 70- 00-1-02." Monsanto's Muscatine, Iowa plant.
20. Iowa Department of Natural Resources, Des Moines, Iowa. "Administrative Order No. 89-WW-10." Monsanto's Muscatine, Iowa plant, March 1989.
21. Iowa Department of Natural Resources, Washington, Iowa. "Discharge Monitoring Report Summary for Outfall 003." Monsanto's Muscatine, Iowa plant, 1991. BUTACHLOR INFORMATION SOURCES CONTINUED:
22. Kamiyama, Michiko, Kamiyama Law Office, Tokyo, Japan. Letter to Sandra Marquardt, 5 July 1990.
23. Marquardt, Sandra. Personal observation and photographs, Philippines, January 1991.
24. Meister, Richard, ed. "Farm Chemicals Handbook." Willoughby, OH: Meister Publishing, 1991.
25. Monsanto Co. Sample pesticide export notification letter, 1987.
26. Monsanto Co. "Material Safety Data Sheet: Butachlor." St. Louis, MO, 1988.
27. Monsanto Co. "Material Safety Data Sheet: Butachlor." St. Louis, MO, 1991.
28. Monsanto Co. "Machete EC label." The Philippines, 1991.
29. Morales, Carlos. "Plaguicidas, defoliantes, reguladores y coadyuvantes registrados en Colombia a traves de la Division de Insumos Agricolas del ICA." Bogota, Colombia, 15 October 1989.
30. New Jersey Department of Health. "Hazardous Substance Fact Sheet: Xylenes." Trenton, New Jersey, 1986.
31. New Jersey Department of Health. " Hazardous Substance Fact Sheet: N-Butyl Alcohol." Trenton, New Jersey, 1985.
32. Ohyama, Tohru, et al. "Fate and Behavior of Herbicides, Butachlor, CNP, Chlomethoxynil, and Simetryne in River Water, Shellfish, and Sediments of the Ishikari River." Bulletin of Environmental Toxicology 39 (1987):555-562.
33. Panama, Ministerio de Salud. "Informe General Alfabetico de Registros, Categoria Agricola," July, 1991.
34. Paraguay, Ministry of Agriculture. "Pesticide Registration List," 1986.
35. Peru, Ministerio de Agricultura. "Listado de Plaguicidas Agricolas Y Sustancias Afines Registrados," July, 1991.
36. Pesticides Trust for Pesticide Action Network International. "The FAO Code: Missing Ingredients." London: Pesticide Trust, 1989.
37. Philippines, Ministry of Agriculture. "Pesticide Registration List," 1989.
38. Royal Society of Chemistry. "Agrochemicals Handbook: Second Ed." Nottingham, UK, 1987.
39. Royal Society of Chemistry. "European Directory of Agrochemical Products: Herbicides." Vol 2, No. 247, Nottingham, UK, 1989.
40. Schneider, Keith. "How Many Product Safety Tests Are Invalid?" Sacramento Bee (23 October 1983):20.
41. Taylor, Robert, EPA. Telephone conversation with Sandra Marquardt, 4 June 1990.
42. Taylor, Robert, EPA. Telephone conversation with Elizabeth Sheldon, 10 February 1991.
43. Thailand, Ministry of Agriculture. "Pesticide Registration List," 1988.
44. Thomson, W.T. "Agricultural Chemicals - Book II: Herbicides," 1986-87 Revision. Fresno, CA: Thomson Pub., 1986.
45. Uruguay, Ministry of Agriculture. "Pesticide Registration List," 1984 and 1989. BUTACHLOR INFORMATION SOURCES CONTINUED:
46. USDA, Economic Research Service. "Foreign Agricultural Trade of the U.S." Washington, DC: GPO, 1988, 1989, 1990 and Jan.-Nov., 1991 supplements.
47. Vincente, Carlos de Linan, ed. "Vademecum de Productos Fitosanitorios y Nutricionales." Spain, 1991.
48. Wesseling, Catharina Dr., et al. "Diagnostico sobre el uso e impacto de los plaguicidas en America Central: Informe de Costa Rica." Auspiciado por la Confederacion de Universitaria Centroamericanas (CSUCA). Costa Rica, (1989):27.
49. Wesseling, Catharina Dr., et al. "Diagnostico del uso e impacto de los plaguicidas en Panama." Auspiciado por la Confederacion Universitaria Centroamericanas (CSUCA). Costa Rica, (1989):12.
50. WHO. "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990- 91." Geneva, Switzerland (1991):25.
2. CARBOSULFAN: By FMC, West Virginia
A. Registration Background
Carbosulfan is produced by FMC in Institute, West Virginia. (29) It is a carbamate compound used as a broad-spectrum stomach poison, contact, and systemic insecticide. Carbosulfan's chemical name is 2,3,-dihydro-2,2-dimethyl-7- benzofuranyl [(di-n-butylamino)thio]-methylcarbamate. (24) It is sold under the trade names "Posse," "Advantage," "Marshal," "Sheriff," "Gazette," and "FMC 350." FMC is the sole patent holder for carbosulfan worldwide. (24,29,38)
FMC has tried for almost ten years to gain domestic registrations and food residue tolerances for carbosulfan. Between 1982 and 1987, FMC submitted nine registration applications and five tolerance petitions for use of carbosulfan on citrus fruits and alfalfa (in 1982), sorghum, apples and pears (in 1983), and alfalfa again (in 1984). To date, EPA has rejected all registration applications and tolerance petitions. The Agency has granted FMC ten Experimental Use Permits (EUP's) for carbosulfan, the first being issued in February, 1982. The EUP's covered crops such as apples, soybeans, citrus, sorghum and alfalfa. (19)
Carbosulfan breaks down into carbofuran, 3-hydroxy- carbofuran and 3-keto-carbofuran. (33,36) This action is of particular importance since carbofuran is highly toxic to birds which frequently mistake the granulated form for a seed. In 1989, EPA proposed a ban on granular formulations of carbofuran due to avian toxicity concerns and the Agency in May, 1991 entered into an agreement with FMC whereby granular formulations of carbofuran will be almost entirely phased out of the U.S. market by September, 1995. (4,18) Despite the U.S. action, FMC intends to continue its export sales of granular formulations of both carbosulfan and carbofuran to other countries. (30)
According to EPA, "A number of data deficiencies currently prevent these applications from proceeding through the registration process." Tolerance petitions have not been granted because of problems with residue data, inadequate methods of validation on certain data, and questions about re- entry data. EPA also cites deficiencies in the requirements pertaining to environmental fate, with special "...concerns over the effects of this chemical relating to groundwater." (19) In 1991, EPA informed FMC that it intended to deny nine pending petitions unless FMC submitted adequate data. (22) Even if FMC decides to pursue the petitions, EPA has no intention of granting registration to a product which breaks down into carbofuran. (17)
The United States is not the only country with concerns over carbosulfan's impact on health and the environment. Malaysia prohibited the manufacturing, sale and import of carbosulfan in 1974 since it poses "hazards under local conditions of use." (40) The Malaysian government believes, "...there are safer alternatives available." (27)
Carbosulfan is the only one of the five never-registered pesticides reviewed in this report which has a WHO/FAO Codex Maximum Limit for pesticide residues. However, the limit (2 mg/kg) is established only for residues on citrus fruits, not for any of the other fruits and vegetables on which it is used. (15)
Also of concern is the use of the highly hazardous chemical methyl isocyanate (MIC) in the production process. The MIC is produced at the neighboring Rhone Poulenc plant and shipped to FMC via an enclosed pipeline. (34) MIC was the chemical released at the Union Carbide pesticide production plant in Bhopal, India in 1984, killing at least 2,500 people. (7)
B. Health and Environmental Hazards Health:
Carbosulfan falls under the equivalent of EPA Class II requiring the word "warning" to be placed on the label. The WHO also classifies it as a Class II, "moderately hazardous" pesticide. (44) Carbosulfan is a cholinesterase-inhibiting carbamate insecticide which causes such symptoms as headaches, weakness, nausea, and blurred vision. More severe effects include excessive respiratory secretion, cyanosis, convulsions, coma, and death. (24) Carbosulfan given orally to pregnant rabbits caused fetotoxic effects and reduction in maternal weight gain. In studies on laboratory rats, carbosulfan caused decreased adult and pup body weights, pup weight gains, neonatal survival and increased incidence of developmental variations. (26) Studies with humans dermally exposed have shown that the higher the temperature and humidity the greater the skin absorption resulting in increased toxicity. (24)
Environment:
Since carbosulfan is a broad-spectrum insecticide, it is indiscriminate in its impact on insects, both predatory and beneficial species.
As mentioned above, a particular environmental concern is the high toxicity to birds of carbosulfan's breakdown product, carbofuran. The granulated form of carbofuran is linked to numerous bird deaths whether through direct ingestion of a granule or of a contaminated soil invertebrate such as an earthworm. Furthermore, carbofuran has secondary effects in that birds of prey can be poisoned when they eat birds which are dead as a result of ingesting carbofuran. (21)
The effect of carbofuran on birds is not only of domestic concern. A German Minister for the Environment for an east German state recently called for a ban on the product following a suspected link with bird deaths. The carbosulfan reportedly was used as a treatment on corn seeds, resulting in the deaths of ravens, ducks and geese. (3)
Use of carbosulfan also threatens water sources, since its breakdown product, carbofuran, is "highly mobile and has a potential to leach...and persist after leaching into groundwater." (20,21) There are no established state or federal water limits or guidelines for discharge of carbosulfan. (42)
C. International Use
Carbosulfan is used in Argentina (8,9), Bangladesh (1), Belgium (23,29), Belize (11), Brazil (12,13), Chile (14), Costa Rica (16,43), Egypt (10), France (23,29), Germany (23,29), Greece (29), Guatemala (25), Indonesia (1,29), Italy (23), Japan (6,10,29), Kenya (35), New Caledonia (2), Pakistan (1), Philippines (1), Rep. of Korea (1,31), South Africa (10), Spain (10,23), Sri Lanka (1), Sweden (29), Thailand (1,37), Turkey (10), United Kingdom (28,29), Yugoslavia (29), and Zimbabwe (5).
It is used on alfalfa, apples, broccoli, citrus, corn, cotton, pears, potatoes, rice, sorghum, soybeans, sugar beets, sugarcane, sunflowers, tomatoes, and other vegetables. (1,2,28,32,39)
Carbosulfan is used on rice in Thailand, the #1 exporter of rice to the U.S. (1,37,41)
U.S. imports in 1987: 72,587 metric tons= 83.8% U.S. imports
in 1988: 92,771 metric tons= 86.8% U.S. imports
in 1989:107,757 metric tons= 88.5% U.S. imports
in 1990:131,380 metric tons= 89.9% U.S. imports
Jan.-Nov. 1991:129,796 metric tons= 88.5% U.S. imports
INFORMATION SOURCES CARBOSULFAN:
1. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Asia." Vol 1 (1991 edition), Bangkok, Thailand, 1990.
2. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Pacific." Vol 2, Bangkok, Thailand, 1990.
3. Agrow. "East German call for carbosulfan ban." PJB Publications Limited, 137 (14 June 1991):12.
4. Agrow. "EPA/FMC agree phase-out of granular carbofuran." PJB Publications Limited, 139 (31 May 1991):16.
5. Agrow. "Incitec's 1990 agchem sales recovery." PJB Publications Limited, 128 (1 February 1991):13.
6. Agrow. "Leading pesticides in Japan in 1990." PJB Publications Limited, 139 (12 July 1991):17.
7. Angier, Natalie, "India's Night of Death." Time 17 December 1984:22-24.
8. Argentina. "Guia de Productos Fitosanitarios para la Republica Argentina," 1988.
9. Argentina, Ministerio de Economia. "Importacion de Productos de Terapeutica Vegetal," 1989.
10. Battelle Europe. "World Pesticide Programme - Insecticides III." Geneva, Switzerland, 1987.
11. Belize, Ministry of Agriculture. "Pesticide Registration Draft: Herbicidas," 1990.
12. Brazil. "Pesticides Registered in Brasil," 1990.
13. Brazil, Posicao Secretaria Agricultura. "Monografias Tecnicas do Ministerio da Saude Sobre Substancias Com Acao Toxica Sobre Animais ou Plantas, de Uso Permitido No Brasil, Em Atividades Agropecuarias E Produtos Domissanitarios." (1985):101.
14. Chile, Servicio Agricola Y Ganandero, Division Proteccion Agricola. Letter to Sandra Marquardt, 12 August 1991.
15. Codex Alimentarius Commission, United Nations Food and Agriculture Organization and World Health Organization Joint Committee. "Guide to Codex Maximum Limits for Pesticide Residues." Part 2, the Netherlands, April 1990.
16. Costa Rica, Ministerio Agricultura Y Ganaderia. "Lista de Plaguicidas al 14/03/91 por Nombre Generico," 1991.
17. Edwards, Dennis, EPA. Telephone conversation with Elizabeth Sheldon, 10 February 1991.
18. EPA. "Environmental News: Pesticide Carbofuran Phased Out Under Settlement Agreement." 14 May 1991.
19. EPA. Letter to Carolyn Brickey, Senate Agriculture Committee, 19 April 1991.
20. EPA. "Pesticides Included in the EPA National Pesticide Survey," 1988. CARBOSULFAN INFORMATION SOURSES CONTINUED:
21. EPA. "Pesticide Fact Sheet: Carbofuran." 5 January 1989.
22. EPA. "Policy Statement Concerning Abandoned and Incomplete Pesticide Petitions." 56 Federal Register (4 September 1991):43759.
23. European Commission. "Registered Pesticides in E.C. Countries: Active Ingredients." Doc. 3010/V1/90, May 1990.
24. FMC Corp. "Material Safety Data Sheet: carbosulfan technical insecticide." Philadelphia, PA, February, 1990.
25. Guatemala, Ministerio de Agricultura Y Ganaderia. "Plaguicidas Agricoias, Fertilizantes Follar, Granulados Y Coadyuvantes," 1991.
26. Hayes, Wayland, et al. "The Handbook of Pesticide Toxicology," Vol 3. New York: Academic Press, 1982.
27. Hian, Tan Soo, Pesticide Board, Ministry of Agriculture, Kuala Lumpur, Malaysia. Letter to Sandra Marquardt, 17 October 1991.
28. Ivens, G.W. ed. "United Kingdom Pesticide Guide." Exeter, Great Britain: British Crop Protection Council Wheatons Ltd. (1990):207.
29. Jacoby, Jeffery, FMC Director of External Affairs. Letter to Sandra Marquardt, 3 May 1991.
30. Jacoby, Jeffery, FMC Director of External Affairs. Letter to Sandra Marquardt, 31 October 1991.
31. Korea, Citizens' Alliance for Consumer Protection of Korea, Seoul, Korea. Letter to Sandra Marquardt, 16 August 1991.
32. Meister, Richard, ed. "Farm Chemicals Handbook." Willoughby, OH: Meister Publishing, 1991.
33. Nigg, H.N. et al. "Leaf, Fruit and Soil Surface Residues of Carbosulfan and Its Metabolites in Florida Citrus Groves." J. Agricultural Food Chem. 32 (1984):80.
34. Niiler, Eric. "Pesticide a Deadly, Double Edged Sword." Gazette Mailer, 16 June 1991.
35. Partow, Hassan, Environment Liaison Centre International, Nairobi, Kenya. Letter to Elizabeth Sheldon, 22 July 1991.
36. Renzi, Barbara and Robert Krieger. "Sublethal Acute Toxicity of Carbosulfan [2,3- dihydro-2,2-dimethyl-7- benzofuranyl(di-n-butylaminosulfenyl)(methyl)carbamate] in the Rat after Intravenous and Oral Exposures." Fundamental and Applied Toxicology 6 (1986):7-115.
37. Thailand, Department of Agriculture. "Pesticides used in crops in Thailand," 1987.
38. Thomson, W.T. "Agricultural Chemicals - Book I: Insecticides," 1989 Revision. Fresno, CA: Thomson Pub., 1986.
39. United Nations Food and Agriculture Organization and the World Health Organization. "Pesticide Residues in Food - 1984: Carbosulfan." Joint Meeting on Pesticide Residues (JMPR), Geneva, Switzerland, 1984.
40. United Nations. "Consolidated List of Products Whose Consumption and/or Sale Have Been Banned, Withdrawn, Severely Restricted or Not Approved by Governments: Agricultural Chemicals." Third Issue, 1987: 178. CARBOSULFAN INFORMATION SOURSES CONTINUED:
41. USDA, Economic Research Service. "Foreign Agricultural Trade of the U.S." Washington, DC: GPO, 1988, 1989, 1990 and Jan.-Nov., 1991 supplements.
42. Waycaster, Jim. Water Resources Section, West Virgina. Letter to Elizabeth Sheldon, 28 August 1991.
43. Wesseling, Catharina Dr., National University, Heredia, Costa Rica. Telephone conversation with Sandra Marquardt, 27 July 1991.
44. World Health Organization. "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990-91." Geneva, Switzerland (1991):15. :
2. HALOXYFOP-METHYL and HALOXYFOP-ETHOXYETHYL:
By DowElanco, Michigan
A. Registration Background
Haloxyfop is a pyridinyl phenoxy compound used as a selective, postemergence herbicide. (22,52) It is produced by DowElanco in Midland, Michigan and sold under the trade names "Galant", "Gallant", "Verdict" and "Dowco 453 ME". (19,21,48) Haloxyfop-methyl's chemical name is methyl 2-(4-((3-chloro-5- trifluoromethyl)-2 pyridinyl)oxy) phenoxy)propanoate. (22)
Since both haloxyfop-methyl and -ethoxyethyl are systemic herbicides, residues "translocate", or travel throughout the plant, including within the edible parts. (21,59)
EPA issued an Experimental Use Permit (EUP) in March 1983 on a "crop destruct basis", whereby the chemical could be used on cotton and soy to collect data to support a registration. This permit was extended two times and expired in April 1989. No tolerance setting was involved since the crops were de- stroyed. (43)
Dow has applied for four product registrations for use of haloxyfop on soybeans (1985), industrial vegetation management (1990), apple orchards (1990) and rice (1991). (28,37) It also has filed four applications with EPA for tolerances in or on foods including: dry land rice (December, 1991), (30) apples (June, 1989) (33), certain soybean products (March, 1988) (32) and eggs, meat, kidney, milk, poultry and soybeans (September, 1985). (29)
EPA has refused both registration applications and tolerance petitions because of concerns regarding oncogenicity. (26)
FDA currently does not have a test method in place for either the -ethoxyethyl or -methyl form of haloxyfop. (35) USDA "does not have a method of detection of haloxyfop and has not tested for it in domestic or imported foods." (57) This is the case despite the potential for its presence in foods as shown by its chemical structure and Dow's efforts to gain food residue tolerances in meat products. (29)
B. Health and Environmental Hazards Health:
Exposure to haloxyfop poses both acute and chronic risks. WHO classifies haloxyfop as Class II, a "moderately hazardous pesticide" with an oral rat LD50 of 393 mg/kg. (62) Repeated exposure can cause eye and upper respiratory irritation, headache and dizziness. (23) Health effects observed in lab animals include harm to the liver, testes, red blood cell components, serum blood cholesterol and cornea. If liquid haloxyfop enters the lungs (aspiration), haloxyfop may cause lung damage or even death due to pneumonia. (22)
In 1988, EPA upgraded its classification of haloxyfop from a Class C, or "possible" human carcinogen (27,31) to a Class B2, or "probable" human carcinogen. (25) This was based on an Agency assessment of studies showing "significant increases in benign and malignant liver tumors in male and female mice and a strong structure activity relationship with other biphenyl ether herbicides" which can cause tumors. (27,31)
The haloxyfop formulations "Verdict" and "Gallant" include xylenes as inert ingredients. (22) These are known to damage the liver, kidneys and bone marrow, be toxic to the fetus and the nervous system and cause low blood cell count. Repeated exposure to xylenes can cause poor memory, concentration and other effects on the brain. (45)
Environment:
Depending on the soil type, haloxyfop's degradation acid has a half-life of between 27 and 100 days. (20,50) Company data tells the user to "Avoid contamination of valuable vegetation. Toxic to fish. Prevent entry to natural waters." (24) Haloxyfop can potentially leach into groundwater following application. (20) There is no waste water discharge limit for this never- registered pesticide under the Clean Water Act, nor does the state require that DowElanco monitor for it. (42)
C. International Use
Haloxyfop is used in Africa (1), Argentina (6,8,10), Australia (9,49), Belgium (34,48), Belize (11), Brazil (4,19,38), Chile (13,14,21), China (2,21), Colombia (15,16,44), Costa Rica (17,53,60,61), Czechoslovakia (48), Dominican Republic (21), El Salvador (63), France (21), Germany (34), Guatemala (36), Honduras (21,39), India (43), Indonesia (2), Italy (5,21,40), Luxembourg (34), Mexico (21,41), the Netherlands (37), New Zealand (24), Norway (37), Pakistan (21), Papua New Guinea (3), Paraguay (46), Poland (19,47,48), Rep. of Korea (2), the Solomon Islands (3), Spain (58), Thailand (2,51,55), the former USSR (19), Uruguay (54), and Yugoslavia (7,21).
Examples of some of the foods and beverages the U.S. imports from countries using haloxyfop-methyl and haloxyfop- ethoxyethyl are as follows:
Beef:
Haloxyfop-methyl is applied to soy, chickpeas, rapeseed, lupines, field peas, navy beans and sunflowers in Australia. (9,49) All of these are fed to cattle. Australia is the #1 exporter of beef & veal to the U.S. (56)
U.S.imports in 1987: 333,231 metric tons= 44.7% U.S. imports
in 1988: 361,805 metric tons= 46.3% U.S. imports
in 1989: 272,949 metric tons= 38.5% U.S. imports
in 1990: 361,775 metric tons= 47.1% U.S. imports
Jan.-Nov. 1991: 335,028 metric tons= 45.7% U.S. imports
Haloxyfop-methyl is applied to soy in Argentina which may be fed to animals. (8,10) Argentina is the #4 exporter of beef and veal to the U.S. (56)
U.S. imports in 1987: 45,954 metric tons= 6.2% U.S. imports
in 1988: 44,769 metric tons= 5.7% U.S. imports
in 1989: 46,093 metric tons= 6.5% U.S. imports
in 1990: 50,925 metric tons= 6.6% U.S. imports
Jan.-Nov. 1991: 57,996 metric tons= 7.9% U.S. imports
Haloxyfop-methyl is used on pasture land in Costa Rica (21), the #5 exporter of beef and veal to the U.S. (56)
U.S. imports in 1987: 27,361 metric tons= 3.7% U.S. imports
in 1988: 23,750 metric tons= 3.0% U.S. imports
in 1989: 19,687 metric tons= 2.8% U.S. imports
in 1990: 18,861 metric tons= 2.5% U.S. imports
Jan.-Nov. 1991: 19,073 metric tons= 2.6% U.S. imports
Palm Oil:
Haloxyfop-methyl is used on palm oil in Indonesia (21), the #2 exporter of palm oil to the U.S. (56) Palm oil is used to fry foods, and is often added to margarine, spreads and frozen foods. (18)
U.S. imports in 1987: 13,888 metric tons= 7.5% U.S. imports
in 1988: 6,382 metric tons= 3.6% U.S. imports
in 1989: 2,364 metric tons= 2.1% U.S. imports
in 1990: 9,608 metric tons= 7.3% U.S. imports
Jan.-Nov. 1991: 10,034 metric tons= 9.1% U.S. imports
Wine:
Haloxyfop-methyl is applied to grapevines in France (21), the #2 exporter of wine to the U.S. (56) U.S. imports
in 1987: 873,007 hectoliters= 26.0% U.S.imports
in 1988: 835,420 hectoliters= 28.2% U.S.imports
in 1989: 845,240 hectoliters= 29.7% U.S.imports
in 1990: 683,030 hectoliters= 27.2% U.S.imports
Jan.-Nov. 1991: 580,988 hectoliters= 27.4% U.S.imports
Additionally, haloxyfop-methyl and/or haloxyfop-ethoxyethyl are used in other countries on crops such as alfalfa, beans, cabbage, carrots, chickpeas, coconut, cotton seed, cucumbers, fruits, mungbeans, onions, potatoes, peanuts, peas, soybeans, sugarbeets, sunflowers, pears, rape and tobacco. (1,2,12,32,40,60,63).
INFORMATION SOURCES
HALOXYFOP:
1. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Africa." Vol 3, Bangkok, Thailand, 1989.
2. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co- operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Asia." Vol 1 (1991 edition), Bangkok, Thailand, 1980.
3. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/ International Co-operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Pacific." Vol 2, Bangkok, Thailand, 1990.
4. Agrow. "DowElanco expects 4-5% growth in '90." PJB Publications Limited, 117 (17 August 1990):2.
5. Agrow. "Dow's Gallant launched in Italy." PJB Publications Limited, 89 (16 June 1989):22.
6. Agrow. "Leading agchems in Argentina in 1988." PJB Publications Limited, 114 (29 June 1990):17.
7. Agrow. "Yugoslavian product approvals." PJB Publications Limited, 80 (10 February 1989):24.
8. Argentina, Camara de Sanidad Agropecuaria y Fertilizantes. "Guia de Productos Fitosanitarios Para la Republica Argentina," 1988.
9. Australia, Queensland Agricultural College. QAC-PESKEM Products, Dept. of Plant Protection, Gatton, Australia, 1986.
10. Battelle Europe. "World Pesticide Programme -- Herbicides II." Geneva, Switzerland, 1985.
11. Belize, Ministry of Agriculture. "Pesticide Registration Draft: Herbicidas," 1990.
12. Canadian Bureau of Chemical Safety. "National Pesticide Residue Limits in Foods." Ottawa, Ontario, Canada (May 1990):117.
13. Chile, Departamento Defensa Agricola. Letter to Sandra Marquardt, 12 August 1991.
14. Chile, Associacion Chilena de Seguridad, Santiago. Letter to Sandra Marquardt, 8 July 1991.
15. Colombia, Instituto Colombiano Agropecuario. "Importacion, Produccion y Ventas de Plaguicidas de Uso Agricola," 1988.
16. Colombia, Ministerio de Salud, Seccion de Toxicologia. "Manual de Informacion Toxicologica: Serie A." Bogota, Colombia, 1988.
17. Costa Rica, Ministry of Agriculture. "Pesticide Registration List," 1989.
18. Department of Commerce. "Fats and Oils Production, Consumption, and Stocks: First Quarter 1991." Washington, DC: GPO, 1991.
19. Dow Chemical Co. "Annual Report." Midland, Michigan, 1989.
20. Dow Chemical Co. "Technical Data on New Verdict: Herbicide." rec'd Feb. 1990. HALOXYFOP INFORMATION SOURCES CONTINUED:
21. DowElanco International Product Registration Manager and Haloxyfop Product Steward, Midland, MI: European Registration Manager, United Kingdom. Telephone conversation with Laura Glassman, 1990.
22. DowElanco. "Material Safety Data Sheet: Haloxyfop ME-F Herbicidal Chemical." Midland, MI, 1991.
23. DowElanco (NZ) Ltd. "Gallant Herbicide: The Ultimate Selective Grasskiller." New Zealand, received 1990.
24. DowElanco (NZ) Ltd. "Material Safety Data Sheet: Gallant." March 1990.
25. Engler, Reto Dr., EPA. EPA Memorandum "List of Chemicals Evaluated for Carcinogenic Potential." (22 March 1991):3.
26. EPA. Correspondence with Senate Agriculture Committee, 1989.
27. EPA. "Information Concerning Haloxyfop Methyl for the Scientific Advisory Panel." 1-2 March 1988.
28. EPA. "Applications to Register Pesticide Products." 50 Federal Register (18 September 1985):37903.
29. EPA. "Pesticide Tolerance Petitions." 50 Federal Register (4 September 1985):35858.
30. EPA. "Pesticide Tolerance Petitions." 56 Federal Register (13 December 1991):65081.
31. EPA. "FIFRA Scientific Advisory Panel." 53 Federal Register (18 February 1988):4885.
32. EPA. "Pesticide Tolerance Petitions." 54 Federal Register (9 March 1988):7569.
33. EPA. "Pesticide Tolerance Petitions." 54 Federal Register (29 June 1989):27422.
34. European Commission. "Registered Pesticides in E.C. Countries: Active Ingredients," Doc. 3010/V1/90, May 1990.
35. FDA. "Statement for the Record: Committee on Agriculture, Nutrition and Forestry, U.S. Senate." 20 September 1991.
36. Guatemala, Ministerio de Agricultura Y Ganaderia. "Plaguicidas Agricoias, Fertilizantes Follar, Granulados Y Coadyuvantes," 1991.
37. Hagaman, John, President and Chief Executive Officer, DowElanco. "Testimony before the U.S. Senate Committee on Agriculture, Nutrition and Forestry." 20 September 1991:4.
38. Hathaway, David. Telephone conversation with Sandra Marquardt re: use of haloxfop-methyl in Brazil, 1990.
39. Honduras, Ministry of Agriculture. "Pesticide Registration List," 1989.
40. Italy, Greenpeace. Letter to Sandra Marquardt, 1990.
41. Mexico, Comision Intersecretarial Para el Control Del Proceso y Uso de Plaguicidas, Fertilizantes y Sustancias Toxicas (CICOPLAFEST). "Catalogo Oficial de Plaguicidas," 1991.
42. Michigan Department of Natural Resources. "Authorization to Discharge Under National Pollutant Discharge Elimination System." Permit No. MI0000868, Dow Chemical Co, Midland, MI, October 1988. HALOXYFOP INFORMATION SOURCES CONTINUED:
43. Miller, Joanne, EPA. Telephone conversation with Laura Glassman, May 1990.
44. Morales, Carlos. "Plaguicidas, defoliantes, reguladores y coadyuvantes registrados en Colombia a traves de la Division de Insumos Agricolas del ICA." Bogota, Colombia, 15 October 1989.
45. New Jersey Department of Health. "Hazardous Substance Fact Sheet: Xylenes." Trenton, New Jersey, 1986.
46. Paraguay, Ministry of Agriculture. "Pesticide Registration List," 1986.
47. Poland, Ministry of Agriculture and Food Production. "Pesticide Registration List," 1990.
48. Royal Society of Chemistry. "European Directory of Agrochemical Products: Herbicides." Vol 2 No. 531, Nottingham, UK, 1989.
49. Short, Kate, Total Environment Center, Australia. Correspondence with Sandra Marquardt re: pesticide use in Australia, 18 February 1990.
50. Smith, Allan. "Persistence Studies with the Herbicide, Haloxyfop-Methyl, in Prairie Field Plots." Bulletin of Environmental Contamination and Toxicology 39 (1987):797-801.
51. Thailand, Ministry of Agriculture. "Pesticide Registration List," 1988.
52. Thomson, W.T. "Agricultural Chemicals - Book II: Herbicides," 1986-87 Revision. Fresno, CA: Thomson Pub., 1986.
53. Treakle, Kay. Photograph of "Gallant" product container, Costa Rica, April 1990.
54. Uruguay, Ministry of Agriculture. "Pesticide Registration List," 1989.
55. US Agency for International Development (AID), Thailand. Telephone conversation with Sandra Marquardt re: pesticide registration in Thailand, 1990.
56. USDA, Economic Research Service. "Foreign Agricultural Trade of the U.S." Washington, DC: GPO, 1988, 1989, 1990 and Jan.- Nov., 1991 supplements.
57. USDA. FOIA response to Sandra Marquardt, 12 September 1991.
58. Vincente, Carlos de Linan, ed. "Vademecum de Productos Fitosanitorios y Nutricionales," Spain. 1991.
59. Weed Science Society of America. "Herbicide Handbook." Champaign, IL, 1979.
60. Wesseling, Catharina, Dr., et al. "Diagnostico sobre el uso e impacto de los plaguicidas en America Central: Informe de Costa Rica." Auspiciado por la Confederacion de Universitaria Centroamericanas (CSUCA). Costa Rica, (1989).
61. Wesseling, Catharina, Dr., Costa Rica. Telephone conversation with Sandra Marquardt, 1990.
62. World Health Organization. "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990-91." Geneva, Switzerland (1991):16.
63. Zepeda, Ernesto Lopez, et al. "Diagnostico sobre el uso e impacto de los plaguicidas en El Salvador." Auspiciado por la Confederacion Universitaria Centroamericanas (CSUCA). San Salvador, October (1988):22.
3. NUARIMOL: By DowElanco, Indiana
A. Registration Background
Nuarimol is a chlorinated pyrimidine fungicide used as a seed- treatment and foliar spray. (21) It is produced by DowElanco, in Lafayette, Indiana (15) and is sold under the trade names "Gauntlet", "Trimidal" and "Triminal". (6,8,21) The chemical name for nuarimol is alpha-(2-chlorophenyl)- alpha-(4-fluorophenyl)-5-pyrimidine-methanol.(8,23)
DowElanco applied to EPA for a food residue tolerance for bananas in February 1983. (7,9) EPA rejected the tolerance due to "oncogenicity [cancer] and teratogenicity [birth defects] concerns." (10) The petition is still pending more than 8 years later. (11) The company has never applied for a tolerance for any other commodity on which nuarimol is used.
B. Health and Environmental Hazards
Health:
Exposure to nuarimol causes both acute and chronic effects. It is moderately acutely toxic, with a WHO classification of Class III, or "slightly hazardous" and a rat oral LD50 of 1250 mg/kg. (24) DowElanco data indicates a single oral as well as inhalation exposure of the product caused laboratory rats to exhibit reduced activity, clonic convulsion (muscle contraction), ataxia (loss of balance and coordination), labored breathing, reduced weight gain, and coma. Laboratory animals exhibited increases in liver weight and enzyme activity and microscopic liver cell changes when repeatedly exposed to the product. (8) The product is also an eye irritant. (8,16,21)
As mentioned above, EPA has concerns over the product's ability to cause cancer and birth defects in lab animals. (10)
Environment:
Nuarimol is moderately hazardous to fish. It falls under EPA toxicity category Class III, with an LC50 of 12.1 mg/l of bluegills. (16)
DowElanco does not have a waste water discharge limit for this never-registered pesticide under the Clean Water Act. It must only `monitor' for it on a monthly basis. The monitoring is conducted by DowElanco and submitted to the Indiana Department of Environmental Management (IDEM). Monitoring reports submitted to IDEM since 1990 show several low detections of nuarimol discharge. (15)
Since nuarimol is systemic, residues "translocate", or travel throughout the plant, including within the edible parts. (21)
C. International Use
Nuarimol is used in Africa (1), Belgium (12,13,19), Colombia (5,17), Czechoslovakia (19), Denmark (12,13,19), France (7,12,13), Germany (12,13), Greece (2,12), Honduras (14), Ireland (12), Italy (3,12), Korea (4,13), Luxembourg (12), Poland (18,19), Portugal (19), Spain (7,12,23), Switzerland (13), United Kingdom (13,19), and Yugoslavia (19).
Some of the beverages the U.S. imports from countries using nuarimol are as follows:
Malt Beverages (beer, ale, etc.):
Nuarimol is applied to barley seed in Germany and the United Kingdom, the #4 and #5 exporters, respectively, of malt beverages to the U.S. (12,19,22)
U.S. malt beverage imports from Germany
in 1987: 1,299,680 hectoliters= 11.8% U.S. imports
in 1988: 1,342,686 hectoliters= 12.2% U.S. imports
in 1989: 1,259,190 hectoliters= 12.3% U.S. imports
in 1990: 1,310,879 hectoliters= 12.6% U.S. imports
Jan-Nov 1991: 993,429 hectoliters= 11.6% U.S. imports
U.S. malt beverage imports from the United Kingdom
in 1987: 302,690 hectoliters= 2.8% U.S. imports
in 1988: 330,343 hectoliters= 3.0% U.S. imports
in 1989: 348,087 hectoliters= 3.4% U.S. imports
in 1990: 375,108 hectoliters= 3.6% U.S. imports
Jan-Nov 1991: 346,649 hectoliters= 4.0% U.S. imports
Wine:
Nuarimol is used on grapevines in Italy, France and Spain which are, respectively, the #1, #2 and #3 exporters of wine to the U.S. (7,12,19,22,23) U.S. wine imports from Italy
in 1987: 1,445,209 hectoliters= 44.7% U.S. imports
in 1988: 1,257,558 hectoliters= 42.5% U.S. imports
in 1989: 1,170,663 hectoliters= 41.2% U.S. imports
in 1990: 1,065,342 hectoliters= 42.2% U.S. imports
Jan.-Nov. 1991: 866,994 hectoliters= 41.0% U.S. imports
U.S. wine imports from France
in 1987: 873,007 hectoliters= 26.0% U.S. imports
in 1988: 835,420 hectoliters= 28.2% U.S. imports
in 1989: 845,240 hectoliters= 29.7% U.S. imports
in 1990: 683,030 hectoliters= 27.2% U.S. imports
Jan.-Nov. 1991: 580,988 hectoliters= 27.4% U.S. imports
U.S. wine imports from Spain
in 1987: 248,988 hectoliters= 7.7% U.S. imports
in 1988: 241,606 hectoliters= 8.2% U.S. imports
in 1989: 222,773 hectoliters= 7.8% U.S. imports
in 1990: 214,611 hectoliters= 8.6% U.S. imports
Jan.-Nov.1991: 152,561 hectoliters= 7.2% U.S. imports
Nuarimol also is used as a fungicide, seed treatment or foliar spray on apples, artichokes, barley, bush beans, chicory, cucumbers, fruits, grapes, melons, nectarines, peaches, peanuts, pears, peppers, strawberries, sugarbeets, wheat and zucchini. (7,20,25)
INFORMATION SOURCES NUARIMOL:
1. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co-operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Africa." Vol 3, Bangkok, Thailand, 1989.
2. Battelle Europe. "Overall Summary - Agricultural Fungicides." Geneva, Switzerland, 1985.
3. Centro Operativo Ortofrutticolo, Italy. Conversation with Greenpeace Italy, 1990.
4. Citizens' Alliance for Consumer Protection of Korea, Seoul, Korea. Letter to Sandra Marquardt, 16 August 1991.
5. Colombia, Ministerio de Salud, Seccion de Toxicologia. "Manual de Informacion Toxicologica: Serie A." Bogota, Colombia, 1988.
6. Day, E.W. and O.D. Decker. "Analytical Methods for Pesticides and Plant Growth Regulators: Nuarimol." Academic Press, Inc., 13(1984):184.
7. DowElanco, International Registration Manager and Regulations Office. Telephone conversation with Sandra Marquardt, 1990.
8. Eli Lilly and Co. "Material Safety Data Sheet: Nuarimol Technical (Trimidal)." Indianapolis, IN, September, 1989.
9. EPA. "Certain Companies; Pesticide Petitions; Elanco Products Co. et al." 48 Federal Register (23 March 1983):12130.
10. EPA. Letter to Senate Agriculture Committee, 1989.
11. EPA. "Policy Statement Concerning Abandoned and Incomplete Pesticide Petitions for Tolerances or Food or Feed Additive Petitions; Solicitation of Public Comment." 56 Federal Register (4 September 1991):43759.
12. European Commission. "Registered Pesticides in E.C. Countries: Active Ingredients," Doc. 3010/V1/90, May 1990.
13. Hagaman, John, President and Chief Executive Officer, DowElanco. "Testimony before the U.S. Senate Committee on Agriculture, Nutrition and Forestry." 20 September 1991:4.
14. Honduras, Ministry of Agriculture. "Pesticide Registration List," 1989.
15. Indiana Department of Environmental Management, Indianapolis, IN. "Permit No. IN 0002861." Eli Lilly and Co. Tippecanoe Laboratories, Lafayette, IN, September 1987.
16. Meister, Richard, ed. "Farm Chemicals Handbook." Willoughby, OH: Meister Publishing, 1991.
17. Morales, Carlos. "Plaguicidas, defoliantes, reguladores y coadyuvantes registrados en Colombia a traves de la Division de Insumos Agricolas del ICA." Bogota, Colombia, 15 October 1989.
18. Poland, Ministry of Agriculture and Food Production. "Pesticide Registration List," 1990. NUARIMOL INFORMATION SOURCES CONTINUED:
19. Royal Society of Chemistry. "European Directory of Agrochemical Products: Fungicides." Vol 1 No. 633, Nottingham, UK, 1989.
20. Scopes, Nigel and Lorna Stables, eds. "Pest and Disease Control Handbook Third Ed." Suffolk: Lavenham Press Ltd., 1989.
21. Thomson, W.T. "Agricultural Chemicals - Book IV: Fungicides," 1988 Revision. Fresno, CA: Thomson Pub., 1988.
22. USDA, Economic Research Service. "Foreign Agricultural Trade of the U.S." Washington, DC: GPO, 1988, 1989, 1990 and Jan.- Nov., 1991 supplements.
23. Vincente, Carlos de Linan, ed. "Vademecum de Productos Fitosanitorios y Nutricionales," Spain, 1991.
24. World Health Organization. "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990-1991." Geneva, Switzerland (1991):19.
25. Worthing, Charles, ed. "Pesticide Manual: A World Compendium." Suffolk: Lavenham Press Ltd. 1983:407.
4. PROTHIOPHOS: By Mobay, Missouri
A. Registration Background
Prothiophos is an organophosphate compound used as a broad- spectrum contact and stomach-poison insecticide. Its chemical name is o-ethyl-O-(2,4-dichlorophenyl)-S-N-propyl dithiophosphate. (33) It has been produced by Mobay Corporation, a U.S. subsidiary of Germany's Bayer AG, in Kansas City, MO since 1976 and is sold under the trade name "Tokuthion". (1,2,23) Prothiophos oxidizes into prothiophosoxon in rats, plants, insects and soil. (25)
Mobay submitted a petition for an import tolerance on Japanese sand pears in November, 1984, (11) when FDA held up 20 tons of imported pears with prothiophos residues at the dock in Seattle, WA. (7,13) On the basis of data submitted to support the tolerance and because other data is still outstanding, EPA has to date refused the petition. (9,10) Studies still missing from the tolerance package and requested by EPA in 1986 include: acute delayed neurotoxicity, 1 year feeding study, oncogenicity studies in two species, teratogenicity studies in two species, reproduction study, gene mutation, and other genotoxic effects. (9) Mobay "did not attempt to respond to this request as a result of the express lack of further interest in pursuing the action by the Japanese Ministry of Agriculture, Fisheries and Forestry." (13)
Prothiophos is the only never-registered pesticide in this report detected by FDA. On 12 occasions since 1982 the Agency has detected illegal residues of the chemical on produce including: three samples of grapes from South Africa (one 5/82 and two 4/84), three samples of pears from Japan (one 9/84, one 10/84 and one 10/85), one sample of mustard greens from Thailand (2/89) and five samples of pickles from Sri Lanka (two 11/90, two 12/90 and one 3/91). (12) Several of the residue levels detected would be in violation of the tolerance levels in the four other countries reviewed which have tolerances on similar commodities. (6) Despite numerous detections on food and a vastly incomplete data base, export continues unabated.
The company has never applied for a domestic registration, nor for an import tolerance on any other commodity the product is used on, including those on which prothiophos has been detected.
EPA filed a complaint against Mobay on January 31, 1990 for exporting Tokuthion to non-English speaking countries with labels written only in English. This is a violation of FIFRA Section 12(a)(1)(E) which requires export labels to be written in English and the language of the importing country. Mobay was fined approximately $18,000 for these violations. (39)
B. Health and Environmental Hazards
Health:
Prothiophos poses both acute and chronic risks. The WHO classifies prothiophos as Class II, a "moderately hazardous pesticide" with an oral LD50 of 925 mg/kg. (38) It is a cholinesterase inhibitor which causes such symptoms as headaches, lightheadedness, weakness, abdominal cramps, nausea, excessive salivation, perspiration, a sense of tightness of chest and constricted pupils. It also causes dermal sensitization. (23)
Bayer teratology studies conducted in 1988 and 1989, and submitted to EPA in 1989, demonstrate prothiophos' ability to cause "significant" birth defects in laboratory rats and rabbits. In Wistar rats, prothiophos caused fetotoxicity in the form of reduced pup and placental weights and incomplete formation of bone (increases in the incidence of delayed/incomplete skeletal ossification). (27) In the study on rabbits, prothiophos caused a decreased gestation rate, an increased abortion rate, a decrease in the mean number of fetuses per dam, and an increase in the rate of resorption and malformations. Malformations included kinked or missing ribs and femoral dysplasia (abnormal femur growth). (15)
Of concern to coonsumers is that the concentration of residues of prothiophos increases in boiled cabbage samples. (31) This finding has serious implications for consumers who boil prothiophos treated fruits and/or vegetables.
Environment:
Prothiophos is toxic to fish. It falls under EPA toxicity Class II with an LC50 of 0.7 mg/l for rainbow trout. (19)
Mobay does not have a waste water discharge limit for this never registered pesticide under the Clean Water Act. Thus, discharge for this pesticide is not required by law to be monitored. Any sampling Mobay may conduct on prothiophos discharge is listed under "total pesticide" output on their monitoring report which is submitted to Missouri's Department of Natural Resources on a quarterly basis. (21)
C. International Use
Prothiophos is used in Australia (3,28), Bahamas (22), Brazil (5), Bulgaria (4), Costa Rica (8,36,37), Egypt (22), El Salvador (4), French Polynesia (2), Honduras (16), Indonesia (1,26,17), Japan (18,34), Malaysia (1,14), Mexico (20), New Caledonia (4), New Zealand (2,4), Papua New Guinea (2), Rep. of Korea (1), Sri Lanka (1,30), South Africa (29), Thailand (1,32) and the former USSR (34).
Examples of some of the food and beverages the U.S. imports from countries using prothiophos are as follows:
Apples:
Prothiophos is used on apple orchards in New Zealand, the #3 exporter of apples to the U.S. (4,24,35) U.S. imports
in 1987: 34,352 metric tons= 25.7% U.S. imports
in 1988: 24,377 metric tons= 19.9% U.S. imports
in 1989: 23,366 metric tons= 20.2% U.S. imports
in 1990: 26,727 metric tons= 25.2% U.S. imports
Jan.-Nov. 1991: 18,320 metric tons= 16.2% U.S. imports
Palm Oil:
Prothiophos is applied to palms in Indonesia, the #2 exporter of palm oil to the U.S. (4,26,35) U.S. imports
in 1987: 13,888 metric tons= 7.5% U.S. imports
in 1988: 6,382 metric tons= 3.6% U.S. imports
in 1989: 2,364 metric tons= 2.1% U.S. imports
in 1990: 9,604 metric tons= 7.3% U.S. imports
Jan.-Nov. 1991: 10,034 metric tons= 9.1% U.S. imports
Pears:
Prothiophos is used on sand pears in Japan, the #4 exporter of pears and quinces to the U.S. (4,13,35) U.S. imports
in 1987: 3,906 metric tons= 11.8% U.S. imports
in 1988: 3,179 metric tons= 9.4% U.S. imports
in 1989: 2,460 metric tons= 6.3% U.S. imports
in 1990: 1,269 metric tons= 3.7% U.S. imports
Jan.-Nov. in 1991: 1,088 metric tons= 4.4% U.S. imports
Tea:
Prothiophos is used on tea in Indonesia, the #3 exporter of tea to the U.S. (4,26,35) U.S. imports
in 1987: 10,395 metric tons= 13.5% U.S. imports
in 1988: 14,376 metric tons= 15.9% U.S. imports
in 1989: 12,293 metric tons= 13.3% U.S. imports
in 1990: 10,649 metric tons= 12.8% U.S. imports
Jan.-Nov. 1991: 11,948 metric tons= 12.5% U.S. imports
Wine:
Prothiophos is used on wine grapes in Australia, the #7 exporter of wine to the U.S. (28,35) U.S. imports
in 1987: 47,602 hectoliters= 1.5% U.S. imports
in 1988: 42,666 hectoliters= 1.4% U.S. imports
in 1989: 38,832 hectoliters= 1.4% U.S. imports
in 1990: 45,815 hectoliters= 1.8% U.S. imports
Jan.-Nov. 1991: 60,117 hectoliters= 2.8% U.S. imports
Additionally, prothiophos is recommended for use on: apples, asparagus, bananas, brocolli, brussel sprouts, cabbages, cauliflower, cherries, chili, citrus, corn, cotton, cucumbers, garlic, grapes, hops, jasmine, kale, lettuce, mulberries, mungbeans, mustard greens, onions, oranges, peanuts, sand pears, persimmons, potatoes, spinach, strawberries, sugarbeets, sugarcane, sweet peppers, tea, tobacco, tomatoes and yerbiro. (1,3,6,12,13,14,17,26,28,33)
INFORMATION SOURCES
PROTHIOPHOS:
1. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/International Co-operation Centre of Agricultural Research for Development (CIRAD). "
Regional Agro-Pesticide Index: Asia." Vol. 1 (1991 edition), Bangkok, Thailand, 1990. 2. Agricultural Requisites Scheme for Asia and the Pacific (ARSAP)/ International Co-operation Centre of Agricultural Research for Development (CIRAD). "Regional Agro-Pesticide Index: Pacific." Vol 2, Bangkok, Thailand, 1990.
3. Australia, Queensland Agricultural College, Dept. of Plant Protection. "QAC- PESKEM Products." Gatton, Australia, 1986.
4. Bayer Germany International Registration. Telephone conversation with Laura Glassman, 1990.
5. Brazil, Posicao Secretaria Agricultura. "Monografias Tecnicas do Ministerio da Saude Sobre Substancias Com Acao Toxica Sobre Animais ou Plantas, de Uso Permitido No Brasil, Em Atividades Agropecuarias E Produtos Domissanitarios." (1985):101.
6. Canadian Bureau of Chemical Safety. "National Pesticide Residue Limits in Foods." Ottawa, Ontario, Canada (May 1990):117.
7. Carlson, Wayne Dr., Mobay Corp. Conversation with Sandra Marquardt, 7 August 1991.
8. Costa Rica, Ministry of Agriculture. "Pesticide Registration List," 1989.
9. Dementi, Brian, Ph.D., EPA. Memorandum to George LaRocca, EPA. Prothiophos, Use on Sand Pears, PP#5E3182," 19 February 1986.
10. EPA. Correspondence with Senate Agriculture Committee, 1989.
11. EPA. "Petition for Tolerances--Tokuthion in or on Pears." 8 November 1984.
12. FDA. "Listing of Pesticides, Industrial Chemicals, and Metals Data by Fiscal Year, Origin, Sample Flag, and Industry/Product Code," 21 August 1991.
13. Grimes, Walter, Vice President for Research and Development, Mobay Corp. "Statement Before the Senate Committee on Agriculture, Nutrition and Forestry." September 20, 1990.
14. Hian, Tan Soo, Pesticide Board, Ministry of Agriculture, Kuala Lumpur, Malaysia. Letter to Sandra Marquardt, 13 March 1991.
15. Holzum, B. Dr. "Study for Embryotoxic Effects on Rabbits Following Oral Administration." Report No. 17041, Bayer Company, Wuppertal, West Germany,
16 August, 1988. 16. Honduras, Ministry of Agriculture. "Pesticide Registration List," 1989.
17. Indonesia, Dept. of Agriculture, National Pesticide Commission. "Pesticides for Agriculture and Forestry." Jakarta, Indonesia, 1990.
18. Kamiyama, Michiko, Kamiyama Law Office, Tokyo, Japan. Letter to Sandra Marquardt, 5 July 1990. PROTHIOPHOS INFORMATION SOURCES CONTINUED:
19. Meister, Richard, ed. "Farm Chemicals Handbook." Willoughby, OH: Meister Publishing, 1991.
20. Mexico, Comision Intersecretarial Para el Control Del Proceso Y Uso de Plaguicidas, Fertilizantes y Sustancias Toxicas (CICOPLAFEST). "Catalogo Oficial de Plaguicidas," 1991
21. Missouri Department of Natural Resources, Division of Environmental Quality Water Pollution Control Program, Jefferson City, MO. "Permit No. MO- 0002526." Mobay Plant, Kansas City, MO., 1989.
22. Mobay Corp., International Registration Manager and Mobay Legal Counsel, Kansas City, MO. Telephone conversation with Laura Glassman, 1990.
23. Mobay Corp. "Material Safety Data Sheet: Tokuthion Technical." Kansas City, MO, December 1990.
24. New Zealand, Pesticides Board. "Pesticides Currently Registered For Use in New Zealand," 1990.
25. Pavlicek, J.R., Director of Administration, Mobay Corp. Letter to Sandra Marquardt, 27 August 1991.
26. P.T. Capricorn, Indonesia Consult Inc. "A Study on the Market of Pesticides in Indonesia 1988." Jakarta, Indonesia: CIC RAYA Group, 1988.
27. Renhof, M. Dr. "Study for Embryotoxic Effects on Rats Following Oral Administration." Report No. 18126, Bayer Company, Wuppertal, West Germany, 22 June 1989.
28. Short, Kate, Total Environment Center, Australia. Telephone conversation with Sandra Marquardt re: pesticide use in Australia, 1990.
29. South Africa, University of Witswatersrand, Johannesburg. Letter to Laura Glassman re: pesticide registration status in South Africa, July 1990.
30. Sri Lanka, Pesticide Registration Office. "Products Registered Under the Control of Pesticides Act No. 33," 1989.
31. Talekar, N.S., et al. "Residual Behavior of Several Insecticides on Chinese Cabbage." Journal of Economic Entomology 70(December 1977):689-692.
32. Thailand, Ministry of Agriculture. "Pesticide Registration List," 1988 and 1990.
33. Thomson, W.T. "Agricultural Chemicals - Book I: Insecticides," 1989 Revision. Fresno, CA: Thomson Pub., 1989.
34. United Nations Environment Program. "International Register of Potentially Toxic Chemicals: Recommendations - Legal Mechanisms `Prothiophos 34643- 46-Geneva,'" Switzerland:17-1.
35. USDA, Economic Research Service. "Foreign Agricultural Trade of the U.S." Washington, DC: GPO, 1988, 1989, 1990 and Jan.- Nov., 1991 supplements.
36. Wesseling, Catharina Dr., National University, Heredia, Costa Rica. Telephone conversation with Sandra Marquardt, 1990. PROTHIOPHOS INFORMATION SOURCES CONTINUED:
37. Wesseling, Catharina Dr., et al. "Diagnostico sobre el uso e impacto de los plaguicidas en America Central: Informe de Costa Rica." Auspiciado por la Confederacion de Universitaria Centroamericanas (CSUCA). Costa Rica, (1989).
38. World Health Organization. "International Programme on Chemical Safety: The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 1990-1991." Geneva, Switzerland (1991):17.
39. Wood, Michael, EPA. "In the Matter of the Mobay Corporation Complaint and Notice of Opportunity for Hearing Docket No. FIFRA No.90-H-3." 31 January 1990.
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