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EBDCs (General Information) EBDC Regulatory Update 6/91

                                            June 14, 1991

Dear Ag Professional:                                                       
Subject: EBDC Regulatory Update                                             

     We want to thank you for your continued support of DITHANE Agricultural 
Fungicide and we want to bring you up-to-date on some of the current 
activities and regulatory events involving DITHANE and other EBDCs relative to 
the EBDC Special Review.  An update of pertinent issues follows. Additionally, 
a summary of the market basket survey information is attached.

Dietary Risk Assessment

     EPA's dietary risk assessment for PD 2/3 was a preliminary assessment 
based on field trial data for estimating exposure to residues and a 
preliminary toxicity factor called Q*.  The registrants have provided 
information to enable the EPA to refine the risk assessment for the conclusion 
of Special Review, which is referred to as PD 4.

     Market Basket survey data will be used for the residue exposure 
assessment in PD 4.  The EBDC/ETU market basket survey was submitted to EPA on 
October 1, 1990.  In this survey, foods were collected from grocery stores 
across the United States to measure actual consumer exposure to EBDC and ETU 
residues.  This was the largest survey of its kind ever conducted.  Overall, 
the survey showed that consumer exposure to EBDCs and ETU is very low.  Eighty 
percent of approximately 6,000 samples had no measurable residues of EBDCs or 
ETU.  Where residues were present, they were only at trace levels.  The 
samples were analyzed with extremely sensitive analytical methods.  In 
general, residues were ten to a hundred times lower than those seen in field 

     Almonds, bananas, apples, and grape samples collected in the market 
basket survey had been analyzed at Craven Laboratories.  Because of 
allegations regarding some of Craven Laboratories procedures used to develop 
the data, the EBDC/ETU Task Force told EPA they would not be relying on those 
data until the Agency had conducted its own review of the matter and any 
concerns had been addressed.  Subsequent to completion of the market basket 
survey, new residue data have been submitted to EPA.  Almonds will be 
regulated by field trial data previously submitted to EPA.

     The market basket survey data will be used to refine the risk assessment. 
Likewise, the EBDC/ETU Task Force has provided data on the toxicity factor, Q* 
to allow a refinement in the toxicity portion of the risk equation.  
Specifically, the Task Force assembled an Independent Panel of noted 
statisticians to review all available toxicology data, including data which 
the Agency did not have available to it when it performed its preliminary Q* 
analysis.  The opinion of the Independent Panel was that the data strongly 
indicated that a lowering of the Q* is appropriate.  The Task Force presented 
the views and analysis of the Independent Panel to the EPA. The Agency is 
currently reviewing these data.

PD 2/3

     EPA issued its regulatory proposal, or PD 2/3, in December, 1989. In PD 
2/3, EPA proposed cancelling potatoes, tomatoes, and bananas based on residues 
developed in controlled field trials.  This is only a proposal, and it is 
legal to use EBDCs on these three crops while Special Review continues.  The 
crops are still on the EBDC labels.  There is no restriction on the use of 
EBDCs or the sale of these crops treated with EBDCs while we are in Special 

PD 4

     The EPA will conclude the Special Review with the issuance of PD 4.  EPA 
is now estimating late fall or early winter for issuance of PD 4.

Tolerance Revocation Proposal

     On May 16, 1990 EPA proposed revoking EBDC tolerances for some 
commodities.  However, it indicated that such action would be held pending 
completion of the Special Review process.  Further, if any uses were cancelled 
through the Special Review, any related tolerances would be eliminated over an 
extended period of time to permit lawfully treated produce and processed 
product to clear trade channels.  According to the proposal, most tolerances 
would remain in effect until December, 1993 or until December, 1994 for apples 
and potatoes, assuming a conclusion of Special Review in spring, 1991.  These 
dates would be extended if the conclusions of Special Review were delayed. 
Therefore, no action to eliminate tolerances is expected until and unless the 
Agency determines that final cancellation of a particular use is appropriate.

      Thank you again for your continued support of EBDC fungicides.  We look 
forward to a successful conclusion of Special Review. Please call me at (215) 
592-3627 if you have any questions.


                                   F. W. Belledin
                                   Sales Manager
                                   Rohm and Haas Company

                  EBDC/ETU Market Basket Survey


In a report submitted to the EPA on October 1, 1990, the EBDC/ETU Task 
Force(1) confirmed that consumer exposure to ethylenebisdithiocarbamate (EBDC) 
fungicides and ethylenethiourea (ETU) was very low.  In general, the residues 
found in foods purchased from grocery stores nation wide as part of the year 
long Market Basket Survey were 10 to 100 times lower than those seen in 
previously conducted field trials.  These results corroborate earlier market 
basket surveys conducted by registrants and Federal and State agencies showing 
that residues of EBDCs and ETU occur only rarely in the marketplace.


(1)Atochem North America, Inc., BASF Corporation, E.l du Pont de Nemours and 
Company, and Rohm and Haas Company.


- Largest food survey of its kind ever conducted.

- Approximately 300 samples of each food item were collected.

- Samples were collected from urban, rural, small and large stores across the 
  United States, generally every two weeks.

- Food items, in varying forms, included: dry beans, broccoli, corn,
  cucumbers, lettuce, meat, milk, onions, potatoes, tomatoes.

- Additional data will be used to support almonds for the future.


                  Number of                 % of Food Samples Where
                  Analyzed Food Samples        Residues Were Not Found(1)
                  ____________________       ___________________________

          EBDC       5,888                            81%
                                                     (91 %)(2)

          ETU        5,890                            82%

(1) Based on limit of quantitation.
(2) Excludes broccoli and onion residues that were not truly EBDCs.


                          EPA                   SURVEY
                         REQUIRED               ACHIEVED
                         ________               ________

        Meat, Milk       0.005 ppm               0.005 ppm
        Crop Items       0.02 ppm                0.005-0.02 ppm

        Meat, Milk       0.001 ppm               0.001 ppm
        Crop Items       0.01 ppm                0.002-0.005ppm


In the six months following the initial report submitted to the EPA by the 
EBDC/ETU Task Force, additional data were collected from monitoring studies of 
fresh grapes, apples and bananas.  The following is a summary of the studies 
and the results submitted to the EPA:

Fresh Grapes

- Seven samples of grapes, grown for commercial use, were collected in
  California in 1990.

- The crop received one to three commercial applications of DITHANE
  fungicide applied through bloom.  The pre-harvest interval was 113 to 150

- No detectable ETU residues were found at an analytical sensitivity of 0.005
  ppm. (EPA required analytical sensitivity of analyses for crop items is 0.01

- Only trace residues of mancozeb were found, and these residues were far
  below the EPA tolerance of 7 ppm.


- Trials took place in six states, using DITHANE fungicide applications (four
  in most cases) up to bloom, or seven applications through second cover.
  (These early season use patterns have a reduced seasonal application rate 
  and a longer pre-harvest interval than the previous full season use pattern,
  so the theoretical dietary risk will be lower.)

- There were no detectable mancozeb residues, or only trace residues of
  mancozeb with an analytical sensitivity of 0.02 ppm.  These residues were
  far below the EPA tolerance of 7 ppm.

- At a limit of detection of 0.005 ppm, no detectable ETU residues were found 
  in eleven of twelve trials.  In one trial, a trace residue of 0.005 ppm was 


- Samples were collected from ships delivering bananas for commercial sale 
  arriving in ports across the United States.  They came from all of the
  banana producing countries that currently export to the U.S.

- All samples, except those from Ecuador, were known to have been treated with 
  EBDCs. Altogether, 169 samples of edible banana pulp were analyzed for
  EBDCs, and 125 of them had been treated. Only one sample had a trace
  residue-0.05 ppm-of EBDC, which was most likely due to contamination
  from peeling the banana.

- Altogether, 98 samples were analyzed for ETU, and 75 of them had been
  treated.  None of the samples had measurable residues of ETU, with an
  analytical sensitivity of 0.005 ppm.


The data from this survey provide a sound basis for which EPA will make a 
regulatory decision regarding the future of these important fungicides 
sometime in 1991.  The results of the studies support the continued 
registration of DITHANE agricultural fungicide, marketed by Rohm and Haas