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sulfur (Kolospray, etc.) Pesticide Reregistration 5/91

United States Environmental Protection Agency
Pesticides And Toxic Substances (H-7508W)
21T-1012 May 1991

EPA R. E. D. FACTS

Sulfur

Pesticide Reregistration

All pesticides sold or used in the United States must be registered by EPA, 
based on scientific studies showing that they can be used without posing 
unreasonable risks to people or the environment. Because of advances in 
scientific knowledge, the law requires that  pesticides which were first 
registered years ago be reregistered to
ensure that they meet today's more stringent standards.

In evaluating pesticides for reregistration, EPA obtains from pesticide 
producers and reviews a complete set of studies showing the human health and 
environmental effects of each pesticide. The Agency imposes any regulatory 
controls that are needed to effectively manage each pesticide's risks. EPA 
then reregisters pesticides that can be used without posing undue hazards to 
human health or the environment.

When a pesticide is eligible for reregistration, EPA announces this and 
explains why in a Reregistration Eligibility Document, or RED. This fact sheet 
summarizes the information in the RED for sulfur.


Sulfur

The element sulfur is a ubiquitous, natural component of the environment. 
Currently, sulfur is registered by EPA for use as an insecticide, fungicide 
and rodenticide on several hundred food and feed crop, ornamental, turf and 
residential sites. It is also used as a fertilizer or soil amendment for 
reclaiming alkaline soils. Sulfur is
 applied in dust, granular or liquid form, and is an active ingredient in
 nearly 300 registered pesticide products. All registered uses of sulfur
 are eligible for reregistration.


Regulatory History

Sulfur has been known and used as a pesticide since very early times, and has 
been registered for pesticidal use in the United States since the 1920s. EPA 
issued a Registration Standard for sulfur in December 1982. The only data 
requirement imposed at that time was a proposal for crop reentry intervals. No 
additional generic data have been required since then.


Health Effects

All of EPA's toxicology data requirements for sulfur have been satisfied for a 
number of years. Sulfur is known to be of low toxicity, and poses very little 
if any risk to human health.

     Acute Effects
Short-term studies show that sulfur is of very low acute oral toxicity and 
does not irritate the skin (it has been placed in Toxicity Category IV, the 
least toxic category, for these effects). Sulfur also is not a skin 
sensitizer. However, sulfur can cause some eye irritation, dermal toxicity and 
inhalation hazards (it has been placed in Toxicity Category III for these 
effects).

     Chronic Effects
Chronic exposure to elemental sulfur at low levels is generally recognized as 
safe. Epidemiological studies show that mine workers exposed to sulfur dust 
and sulfur dioxide throughout their lives often had eye and respiratory 
disturbances, chronic bronchitis and chronic sinus effects. However, no known 
risks of oncogenic, teratogenic, or reproductive effects are associated with 
the use of sulfur. Also, sulfur has been shown to be non-mutagenic in 
microorganisms.


Routes Of Exposure 

We are all exposed to sulfur, since this element is ubiquitous in the 
environment- Sulfur in its various forms represents about 1.9 percent of the 
total weight of the earth. Most terrestrial and aquatic environments contain 
high levels of sulfur.


     Through the Diet
People may be exposed to small amounts of sulfur through the food supply. 
However, since sulfur does not pose any relevant toxic effects, no dietary 
risk assessment was performed. Sulfur is generally recognized as safe, as 
noted in 40 CFR 180.2(a), so no tolerances (or residue limits) need be 
established for residues of sulfur in or on food or feed commodities.

     During Application
People can be exposed to sulfur while mixing, loading or applying the 
pesticide, and while working among treated crops. Based on incidents of skin 
and eye irritation reported among field workers in California, EPA has 
determined that a hazard exists for workers reentering fields following foliar 
application of sulfur dust. Therefore, a 24-hour reentry interval and 
protective clothing requirements must be added to the labeling of all outdoor 
use sulfur products.


Environmental Hazards

All the environmental fate and ecological effects data requirements are 
satisfied for sulfur. This ubiquitous substance does not cause unreasonable 
adverse effects in the environment when used according to approved labeling, 
and poses little or no hazard to non-target organisms.

     Environmental Fate
In the 1982 Registration Standard, all environmental fate data requirements 
were waived for sulfur based on the fact that it is a natural component of the 
environment. The use of elemental sulfur as a pesticide or a soil amendment is 
not an environmental concern because it becomes incorporated into the natural 
sulfur cycle.

     Ecological Effects
In six studies on ecological effects (involving bobwhite quail, two fish 
species, daphnia, mysid shrimp and honey bees), sulfur has been shown to be 
practically non-toxic to the species tested. Thus, although there is potential 
for non-target organisms to be exposed to sulfur, little hazard to these 
species is expected to result.


Additional Data Required 

The generic data base supporting the reregistration of products containing 
sulfur has been reviewed and determined to be complete. No further generic 
data are required to support reregistration. Some product-specific data are 
being required as described in Appendix D to the Reregistration Eligibility 
Document.


Product Labeling

All end-use outdoor sulfur product labels must bear an updated  Changes 
Required  water contamination warning, and a 24-hour reentry statement and 
protective clothing requirements to protect handlers and field workers from 
adverse skin and eye effects. Please see the Reregistration Eligibility 
Document for the exact wording of these required label - statements.


Regulatory Conclusion

- The studies available to EPA indicate that the element sulfur is of low 
toxicity, and its use as a pesticide poses very little known hazard to people 
and nontarget species.

- Sulfur dust can cause eye and skin irritation to people who handle the 
pesticide or come into contact with treated foliage during field work. 
Therefore, a 24-hour reentry interval and protective clothing requirements 
must be included on all outdoor sulfur product labels.

- The pesticide sulfur can be used without causing unreasonable adverse 
effects in people or the environment. Therefore, all pesticide products 
containing sulfur as the sole active ingredient are eligible for 
reregistration.

- EPA will reregister individual products containing sulfur once product 
specific data and revised product labeling are submitted to and accepted by 
the Agency.


For More Information

EPA is requesting public comments on the Reregistration Eligibility Document 
for sulfur during a 60-day time period, as announced in a Notice of 
Availability published in the Federal Register. To obtain a copy of the RED, 
or to submit written comments, please contact the Public Response and Program 
Resources Branch, Field Operations Division (H-7506C), Office of Pesticide 
Programs, U.S. EPA, Washington, D.C. 20460, telephone 703-557-4436, or Fax 
#703-557-1884. Please note that after the comment period closes, the RED will 
be available from NTIS, at the address and telephone number below.

To obtain a copy of the December 1982 Registration Standard for sulfur, please 
contact the National Technical Information Service (NTIS), 5285 Port Royal 
Road, Springfield, VA. 22161, telephone 703- 487-4650. Request document #PB86-
102043.

For more information about sulfur or about EPA's pesticide reregistration 
program, please contact the Special Review and Reregistration Division (H-
7508W), Office of Pesticide Programs, U.S. EPA, Washington, D.C. 20460, 
teleph

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