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EBDCs (General Information) EPA's Proposed Regulatory Decision 12/89

                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460

                               December 1, 1989

                                 OFFICE OF
                       PESTICIDES AND TOXIC SUBSTANCES


NOTE TO:  EPA REGIONAL OFFICES AND STATE LEAD AGENCIES


     EPA's proposed regulatory action on the EBDCs is scheduled to be
announced at 11:00 a.m. EST on Monday, December 4.  We have enclosed
materials which you may find useful in explaining the Agency's decision.
Please do not distribute or discuss any of this information until after
the announcement.

Additional materials will be forwarded to you after the announcement has
been made.


                     Stephen L. Johnson, Director
                     Field Operations Division



                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460


                               December 4, 1989

                             THE EBDC PESTICIDES
                 AND EPA'S PR0P0SED RBGULATORY DECISION

Facts for Consumers
___________________


The Environmental Protection Agency (EPA) is proposing to ban the use of
the EBDC (ethylene bisdithiocarbamate) pesticides on many food crops
after determining that the cumulative health risks of these uses
outweigh the benefits.  At the same time, EPA is proposing to allow the
continued use of the EBDCs on 10 other food crops, where the risks
appear to be negligible and outweighed by greater benefits.

This action is being taken to reduce consumers' exposure to these
pesticides in food.  Although EPA believes that the American food supply
is safe, the action EPA is proposing should make it still safer.

Food safety is one of the highest priorities of both the President and
the Federal government.  EPA, the Food and Drug Administration (FDA) and
the U.S. Department of Agriculture (USDA) share the goal of ensuring
public health, environmental protection, and a safe and abundant food
supply.  President Bush recently announced his Food Safety Plan, a
comprehensive new program involving the three agencies which will
enhance food safety for all Americans.

The United States' food supply is among the safest, most plentiful, and
most affordable in the world.  Agricultural pesticides play an important
role in the production of food.  However, it is important to recognize
that all pesticides are inherently toxic to something -- none are
completely risk-free.  The risk posed by a pesticide depends not only on
its toxicity but also on the amount of it to which people are exposed.
If exposure is very low, the risk may be very small.

EPA sets standards for maximum pesticide residues allowed in food.
These pesticide residue limits, or tolerances, are intentionally set
well below the point at which unreasonable effects are believed likely
to occur.  FDA and USDA monitor the U.S. food supply to ensure that
these safety standards are met.

Although EPA's proposed decision on the EBDCs addresses cancer risks, it
is important to realize that the Agency's concern is based on potential
risks to people, derived from laboratory animal studies.

Fresh fruits and vegetables are an essential part of a healthful diet.
The National Research Council, in its 1989 study entitled Diet and
Health - Implications for Reducing Chronic Disease Risk, recommends that
Americans consume more fresh fruits and vegetables to lessen the risk of
chronic disease.  That study went on to say that there is no evidence to
indicate that foods containing low levels of pesticide residues present
a significant health risk.

In regulating pesticides, EPA evaluates their potential risks and, where
necessary, controls risks using measures intended to limit people's
exposure to these substances.  This risk reduction may be done through a
range of actions such as banning the use of a pesticide completely,
restricting its use to specific crops, or limiting the amount or
frequency of its application.  Through this process of risk management,
and by weighing pesticide risks and benefits as required by law, EPA
seeks to ensure that the benefits of a safe and abundant food supply
will continue to be realized for all American consumers.

Q1.  WHAT ARE THE EBDCs?

The ethylene bisdithiocarbamates or EBDCs -- mancozeb, maneb, metiram,
nabam and zineb -- are a group of pesticides used to control fungi,
primarily on a wide variety of fruits, vegetables, ornamental plants,
and on turf grass.  EBDC fungicides are used in commercial agriculture
and in home gardens to protect food crops against damage by mold, mildew
and fungal diseases.  They also are used on home lawns and ornamental
plants, and in some industrial processes such as making paper.

Q2.  WHAT RISKS DO THE EBDCs POSE?

The EBDC fungicides break down into ETU (ethylenethiourea), a metabolite
common to all EBDCs.  Laboratory animals have developed cancer, thyroid
disorders and birth defects after being fed high levels of ETU.  People
who eat foods containing EBDC residues in amounts found on crops at
harvest time are not at risk for thyroid disorders or birth defects, but
they may have an increased risk of developing cancer.

However, people who handle or apply EBDC fungicides without wearing
protective clothing may increase their risk of developing cancer or
thyroid problems, or of having children with birth defects.

Q3.  WHAT DO YOU MEAN BY SAYING THAT THE EBDCs MAY CAUSE CANCER?
DOESN'T EPA KNOW FOR SURE?

In assessing the risks of any pesticide, EPA uses data from laboratory
animal studies to learn about possible adverse health effects in people.
However, there is uncertainty in using laboratory animal data to predict
what will happen in humans.  To be on the safe side, EPA uses
conservative methods to estimate how likely it is that cancer will occur
in people exposed to a pesticide, once the pesticide has been found to
cause cancer in laboratory animals.

The degree of risk posed by a pesticide depends not only on its toxic
effects, but also on the extent to which people are exposed to it
through their diets or when applying the pesticide.  One very important
point is that EPA currently needs more information on how much EBDC
residue actually remains on food crops when they are consumed, at the
"dinner plate."  In the absence of such actual human dietary exposure
data, EPA has made assumptions about exposure, and has taken into
account the percent of the crop typically treated and the effect of
washing and peeling treated food.  In this way, EPA has attempted to
develop exposure estimates that are typical of average dietary exposure.

EPA is in the process of getting more information about the EBDC
residues actually found on foods at the time they are purchased by
consumers.  These market basket or grocery store survey data should
enable us to improve our current exposure and risk estimates.  We
believe the market basket data may show that residues of the EBDCs
decline between the time crops are harvested and the time they are sold
in grocery stores.  If this is true, the EBDCs may pose lower risks than
our estimates so far indicate.

Q4.  CAN  EBDC  RE5IDUES  BE REMOVED FROM FRUITS AND VEGETABLES?  HOW
CAN I REDUCE MY EXP0SURE TO THE EBDCs IN FOODS?

EBDC residues break down rapidly in fruits and vegetables after these
fungicides are used on the farm.  Remaining residues of the EBDCs are
found primarily on the surface of fruits and vegetables.  You can reduce
your exposure to the EBDCs by removing these surface residues before
cooking or eating produce.  Wash fresh fruits and vegetables with water,
and peel them or scrub them with a brush, as appropriate.  Throw away
the outer leaves of leafy vegetables such as lettuce and cabbage unless
such trimming has already been done by your grocer.

Q5.  WHAT HAPPENS WHEN YOU COOK PRODUCE THAT CONTAINS RESIDUES OF THE
EBDCs?  WHAT EFFECT DOES COOKING OR PROCESSING HAVE ON EBDC RESIDUES IN
FRUITS AND VEGETABLES?

The best way to minimize exposure to the EBDCs and ETU is by washing
and, if possible, scrubbing and peeling fresh fruits and vegetables to
remove as much surface pesticide residue as possible before cooking or
eating these foods.

Cooking or processing most fruits and vegetables containing EBDC
residues reduces the amount of EBDCs and increases the amount of ETU in
the food.  This is because a portion of the EBDCs is converted to ETU
through heating.  The human body also converts EBDC residues to ETU
while digesting food.

EPA has some limited data indicating that ETU residues, like the EBDCs,
are unstable and may decline after they are formed.  Still, to avoid
exposure to ETU and the EBDCs, thoroughly wash and scrub or peel fresh
produce before cooking or eating it.

Q6.  WHAT IS EPA DOING ABOUT THE EBDCs?

Based on an intensive risk/benefit review, EPA is proposing to cancel,
or permanently stop, most food uses of the EBDCs.  EPA is proposing to
allow continued use of the EBDCs on 10 crops.  EPA believes that the
potential risks posed by these uses are so low as to be acceptable.

EPA also is proposing to cancel homeowner uses of the EBDCs that pose
unreasonable risks.  For the EBDC uses that will remain, EPA will
require that workers wear protective clothing when handling and applying
these pesticides, to guard against an increased risk of cancer, thyroid
problems and birth defects.

Q7.  IF EATING FOODS TREATED WITH EBDCs MAY BE DANGEROUS, WHY DOESN'T
EPA TAKE ALL EBDC FOOD USES OFF THE MARKET, IMMEDIATELY?

EPA is not taking action to immediately halt all uses of the EBDCs
because we believe that the risks posed by the EBDCs during the
relatively short time it will take to remove many of these products from
the market are not unreasonable.  In addition, voluntary action by four
of the major manufacturers of the EBDCs will stop many uses of these
fungicides, thereby reducing consumers' exposure during the time
required by EPA to effect a final regulatory decision.

Further, EPA will not take all EBDC food crop uses off the market.  In
our view, certain EBDC uses do not pose unacceptable long-term risks,
and provide significant benefits to farmers and consumers which offset
these hazards.  The risks posed by different EBDC crop uses vary because
of differences in agricultural practices among crops, variations in the
handling, processing and preparation of different foods, and varying
contributions of foods to the typical American diet.

Q8.  TO BE ON THE SAFE SIDE, SHOULD I STOP  EATING FRUITS AND VEGETABLES
THAT MAY BE TREATED WITH THE EBDCs UNTIL EPA MAKES A FINAL CANCELLATION
DECISION?

No.  You should continue to eat fruits and vegetables while EPA
completes its review of the EBDCs.  A report issued by the National
Research Council in 1989 recommends that people eat more fresh fruits
and vegetables to avoid risks of cancer and other chronic diseases.  The
report notes that even though these foods may contain low levels of
pesticide residues, the potential small increased health risks would be
greatly outweighed by the benefits to good health from greater fruit and
vegetable consumption.formed.  Still, to avoid exposure to ETU and the
EBDCs, thoroughly wash and scrub or peel fresh produce before cooking or
eating it.

Q6.  WHAT IS EPA DOING ABOUT THE EBDCs?

Based on an intensive risk/benefit review, EPA is proposing to cancel,
or permanently stop, most food uses of the EBDCs.  EPA is proposing to
allow continued use of the EBDCs on 10 crops.  EPA believes that the
potential risks posed by these uses are so low as to be acceptable.

EPA also is proposing to cancel homeowner uses of the EBDCs that pose
unreasonable risks.  For the EBDC uses that will remain, EPA will
require that workers wear protective clothing when handling and applying
these pesticides, to guard against an increased risk of cancer, thyroid
problems and birth defects.

Q7.  IF EATING FOODS TREATED WITH EBDCs MAY BE DANGEROUS WHY DOESN'T EPA
TAKE ALL EBDC FOOD USES OFF THE MARKET, IMMEDIATELY?

EPA is not taking action to immediately halt all uses of the EBDCs
because we believe that the risks posed by the EBDCs during the
relatively short time it will take to remove many of these products from
the market are not unreasonable.  In addition, voluntary action by four
of the major manufacturers of the EBDCs will stop many uses of these
fungicides, thereby reducing consumers' exposure during the time
required by EPA to effect a final regulatory decision.

Further, EPA will not take all EBDC food crop uses off the market.  In
our view, certain EBDC uses do not pose unacceptable long-term risks,
and provide significant benefits to farmers and consumers which offset
these hazards.  The risks posed by different EBDC crop uses vary because
of differences in agricultural practices among crops, variations in the
handling, processing and preparation of different foods, and varying
contributions of foods to the typical American diet.

Q8.  TO BE ON THE SAFE SIDE, SHOULD I STOP EATING FRUITS AND VEGETABLES
THAT MAY BE TREATED WITH THE EBDCs UNTIL EPA MARES A FINAL CANCELLATION
DECISION?

No.  You should continue to eat fruits and vegetables while EPA
completes its review of the EBDCs.  A report issued by the National
Research Council in 1989 recommends that people eat more fresh fruits
and vegetables to avoid risks of cancer and other chronic diseases.  The
report notes that even though these foods may contain low levels of
pesticide residues, the potential small increased health risks would be
greatly outweighed by the benefits to good health from greater fruit and
vegetable consumption.

Four major manufacturers of the EBDCs have volunteered to remove many
agricultural uses from their registrations and product labels.  Use of
the EBDCs on food crops are expected to decrease significantly over
time, as a result.  Therefore, EPA believes that the risk to consumers
while EPA completes its review of the EBDCs is not unreasonable.

Q9.  EVEN IF CERTAIN USES OF THE EBDCs ARE SAFE ENOUGH TO REMAIN ON THE
MARKET, ISN'T IT DANGEROUS TO EAT A DIET THAT CONSISTS OF MANY OR ALL OF
THESE RETAINED, EBDC-TREATED FOODS?  IN OTHER WORDS, IS IT SAFE TO EAT
ALL THE FOODS AT THE SALAD BAR?

In evaluating food crop uses of the EBDCs, EPA has considered the
exposure from each individual food crop as well as the combined exposure
from all the treated food crops.  We believe that, over a lifetime, it
would be prudent for consumers to eat fewer EBDC-treated foods than they
do now.  Therefore, EPA is taking action to eliminate EBDC uses that,
based on our current assessments, appear to pose the greatest risks.  In
this way, EPA will act to ensure that consumers can safely eat the
remaining EBDC-treated food crops throughout their lives.

Q10.  HOW MUCH OF THE EBDCs REMAIN ON THE FOOD WE EAT?

To evaluate consumers' exposure to the EBDCs, EPA used the best data
available on EBDC residues in foods.  For some crops, the best data came
from field studies which show the average levels of the EBDC fungicides
that are likely to remain on treated crops as they leave the farm.  For
other crops, data from processing and cooking studies were available.
Estimates of the percentage of the crop actually treated with EBDCs also
were used.  Your exposure may actually be higher or lower than EPA
estimated, depending on a number of factors such as the percentage of
your food that was treated, and how thoroughly your fruits and
vegetables were washed.

Even though EPA's exposure estimates used the best food residue data
currently available, the Agency is requiring the EBDC manufacturers to
conduct a survey of EBDC and ETU residues on fresh, frozen and canned
foods sold in grocery stores.  If obtained, such survey data should
enable EPA to more closely estimate people's dietary exposure to the
EBDCs.

Qll.  IS IT SAFE FOR BABIES AND CHILDREN TO EAT FRUIT AND VEGETABLES
THAT CONTAIN EBDC RESIDUES?

In estimating the potential risk of eating foods that contain residues
of the EBDCs, EPA has taken into account the fact that infants and
children eat proportionately greater amounts of certain foods than
adults do.  The Agency has concluded that babies and children, like
adults, will not encounter unreasonable risk during the time it will
take the Agency to complete its review of the EBDCs.

Q12.  DO IMPORTED FOODS ALS0 CONTAIN EBDC RESIDUES? HOW IS THE
GOVERNMENT ENSURING THE SAFETY OF IMPORTED FOODS CONTAINING RESIDUES OF
THE EBDCs?

Imported foods currently may contain EBDC residues. Once EPA cancels a
number of EBDC food crop uses, the Agency will revoke the corresponding
tolerances, ultimately making it unlawful to ship those crops into the
U.S. if they contain EBDC residues.  These actions are designed to
prevent imported foods from bringing the EBDCs back into the diet of the
American consumer.

Q13.  EPA IS PLANNING TO LEAVE ON THE MARKET SEVERAL EBDC PRODUCTS WITH
HOMEOWNER USES.  HOW CAN I AVOID RISKS OF CANCER, THYROID EFFECTS AND
BIRTH DEFECTS WHILE USING THESE PRODUCTS?

To be sure that you use an EBDC fungicide as safely as possible, as with
any pesticide, you must read and follow all the directions and
precautions on the product label.  Even if you have used the product
before, read the label thoroughly before you begin preparations to use
it again.  Apply EBDCs only to those crops or sites which are listed on
the product label.  Be sure to wear protective clothing while mixing and
applying the EBDCs, and wash this clothing separately from other laundry
when you are done.  If any of the pesticide gets on your skin, wash it
off with soap and water.  Follow label instructions to wait a certain
amount of time between using EBDCs and picking and eating food crops.

Q14.  HOW CAN I SAFELY DISPOSE OF EBDC PRODUCTS THAT I NO LONGER WANT TO
USE?

If you have an EBDC product that you do not want you should dispose of
it in accordance with the instructions on its label and any local
disposal requirements.  Remember to store it securely, out of children's
reach, until you are ready to dispose of it.  Be aware, however, that
the safest and most environmentally sound way to dispose of your product
may be to use it, in accordance with its label directions and
precautions.

Before disposing of the product, check with your State or county waste
management agency, or with your U.S. EPA Regional Office, to determine
if there are any local requirements that you must consider in addition
to the label instructions.

Household hazardous waste collection programs, available in many areas,
provide an excellent opportunity to safely dispose of small amounts of
unused, unwanted pesticides.  If such a program is not available in your
area, you may find that you can dispose of your EBDC pesticide with your
regular trash.  Wrap each product container in several layers of
newspapers, tie securely, and dispose of it along with other household
waste.


                          CROPS AFFECTED BY
                  EPA's PROP0SED REGULATORY DECISION
                        ON THE EBDC PESTICIDES


Uses Proposed to be Retained:

   Almonds                    Onions
   Asparagus                  Peanuts
   Cranberries                Sugar Beets
   Figs                       Sweet Corn
   Grapes                     Wheat


Uses Proposed to be Cancelled:

   Apples                     Broccoli               Peppers
   Apricots                   Brussels Sprouts      *Potatoes
  *Bananas                    Cabbage                Rhubarb
   Barley                     Cantaloupe             Rye
   Casaba Melons              Carrots                Squash
   Crenshaw Melons            Cauliflower            Spinach
   Cucumbers                  Celery                *Tomatoes
   Eggplant                   Collards               Turnips
   Endive                     Mustard Greens         Watermelon
   Lettuce                    Nectarines             Field Corn
   Pineapple                  Oats                   Cotton
   Pumpkin                    Papaya                 Crabapple/Quince
   Green and Dried            Peaches                Fennel
     Beans                    Pears                  Honeydew Melon
   Lima Beans                 Pecans                 Kale
   Kohlrabi

*EPA cancellation proposals that go beyond industry action.


For additional information on the EBDCs, call the National Pesticides
Telecommunication Network toll-free at 1-800-858-7378, or contact your
U.S. EPA Regional Office



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