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Parathion (Ethyl) - Voluntary Cancellation Notice 12/91

DEC. 13, 199l

Dear Addressees:

I am writing to provide you with information about today's announcement
by the Environmental Protection Agency regarding the pesticide parathion.
Enclosed, please find a copy of a Press Advisory, a set of Questions and
Answers, and a brochure that explains how to comply with the reporting
requirements that apply to certain holders of canceled parathion products.
These attachments provide several phone numbers that you may call if you have
additional questions.

Sincerely

Stephen L. Johnson, Director
Field Operations Division (H7506C)

Enclosures

NOTICE OF VOLUNTARY CANCELLATION OF PARATHION
REGISTRATIONS EXCEPT FOR USE ON FIELD CROPS

QUESTIONS AND ANSWERS

1. WHAT ACTION IS EPA TAKING?

EPA is announcing receipt of requests from a number of registrants to
voluntarily cancel registrations of pesticide products containing ethyl
parathion. The Agency is also issuing a cancellation order for these
registrations. The requests for voluntary cancellation are the result of an
agreement between the Agency and the registrants in September 1991, which
restricts the terms and conditions of parathion use in the United States.
Because of the risks that may be associated with the use of parathion under
the previous terms and conditions of use, EPA is granting the requests for
voluntary cancellation. The registrants agreed to voluntarily withdraw all
old registered uses (over 80) including all use on fruit, nut, and vegetable
crops. Through this cancellation order, EPA is canceling the registrations of
125 products containing parathion. Thirty four new registrations subject to
severe restrictions have been issued for 9 field crops: alfalfa, barley,
corn, canola, cotton, sorghum, soybeans, sunflower, and wheat. (The use on
canola will not be permitted until the registrant provides the Agency with the
acceptable results of residue tests). The Agency, however, is still
considering regulatory action to cancel these remaining uses based on
continuing concerns about the risks of exposure to workers and birds.

Additionally, this notice requires anyone (except end-users who are not
commercial applicators) possessing any parathion product which has had its
registration canceled, to notify EPA and appropriate State and local officials
of the quantity of such pesticide and the place where the product is located.
(See question 3).

Public comment is also being requested on what, if any, action EPA should take
regarding the reduction and/or revocation of tolerances (allowable residue
levels) for parathion on foods. (See question 19).

2. WHY DID EPA AND THE REGISTRANTS OF PARATHION REACH AN AGREEMENT REGARDING
PARATHION

Ethyl parathion is one of the most acutely toxic pesticides registered with
EPA. After assessing the risks and benefits associated with registered uses
of parathion, the Agency determined that the risks of exposure to agricultural
workers were unacceptable. The settlement agreement cancels those application
methods and work practices posing the highest risks of exposure to parathion
while imposing new restrictions on the remaining field crop uses. "Ethyl
parathion" should not be confused with "methyl parathion," a less toxic
pesticide not affected by these actions.

3. WHO MUST REPORT THAT THEY POSSESS CANCELED PARATHION PRODUCTS?

Any producer or exporter, registrant, applicant for a registration, applicant
or holder of an experimental use permit, commercial applicator, or any other
person who distributes or sells any pesticide, and who possesses any pesticide
products containing parathion which have been canceled must report the
quantity and location of the canceled product. Except for commercial
applicators, end users are not required to report this information

4. WHERE DO I REPORT THIS INFORMATION?

Persons who are required to report canceled parathion products in their
possession must notify EPA, State and local authorities. Below is a summary of
where to report. More detailed information is given in the attached 6(g)
Notification leaflet.

A. EPA

Director, Compliance Division, Office o Compliance Monitoring (EN-342),
U.S. Environmental Protection Agency, 401 M St., SW., Washington, DC 20460.
Envelopes must be marked "Attention: FIFRA Section 6(g) Information; and

B. State

Chief Pesticide Regulatory Official, of the agency in the State
government which enforces the State pesticide laws where the canceled ethyl
parathion pesticide product is stored. Envelopes must be marked, "Attention:
FIFRA Section 6(g) Information." Information on the appropriate official to
receive the FIFRA Section 6(g) information in each State is available from
EPA's Parathion Help Line 1-800-382-1132, and

C. Local

Chair of the Local Emergency Planning Committee (LEPC), for the location
where canceled ethyl parathion is stored. Envelopes should be marked,
"Attention: Notification of Possession of Canceled Pesticides." To identify
the name and address of the chair of the LEPC contact the State Emergency
Response Commission or call the Emergency Planning and Community Right-to-Know
(EPCRA) Information Hotline at 1-800-535-0202.

5. WHEN IS THE DEADLINE TO REPORT THIS INFORMATION?

Registrants must report this information by January 6, 1992. Producers,
exporters, applicants for registration, applicants or holders of experimental
use permits, dealers, distributors, and retailers must report by January 15,
1992. Commercial applicators must report by January 31, 1992.

6. UNTIL WHAT DATES CAN EXISTING STOCKS OF PRODUCTS CONTAINING PARATHION BE
SOLD ?

Sale by registrants and supplemental distributors of existing stocks of
canceled pesticide products containing parathion (products labeled for uses
other than the 8 field crops) is prohibited. (Use on canola is prohibited
until the required data are provided and the Agency approves the use.)

Sale and distribution by all other persons of these canceled products is
prohibited unless the stocks are restickered or relabeled with the approved
label (aerial application only on the 8 field crops with additional protective
measures) and are in containers which are compatible with the use of the
engineering controls required under the terms of the agreement. The
additional protective measures are summarized in question 15.

7. CAN I CONTINUE TO USE MY STOCKS OF PARATHION.

Until December 31, 1991, any use of existing stocks of canceled product prior
must be in accordance with either the directions for use contained in the
Agreement or the previously-approved labeling accompanying that product.
After December 31, 1991, all use of existing stocks of parathion products will
be prohibited except when used in accordance with all of the terms in the
settlement agreement and only on the approved field crops.

8. HOW WILL CANCELED PRODUCTS CONTAINING PARATHION BE DISPOSED OF?

EPA intends to take several steps to facilitate proper management of canceled
stocks. The Agency intends to meet with registrants, retailer and distributor
trade associations, State pesticide regulators and agricultural officials, and
other organizations to discuss the status of canceled stocks and their proper
management. In addition to disposal, other management options include
relabeling or reformulation for uses that have not been canceled. EPA hopes
these efforts will lead to voluntary recalls of parathion products.

If you are a holder of canceled parathion, EPA recommends that you contact
your distributor or the manufacturer to arrange for return of your products.
If they will not take the products back, you will be responsible for disposing
of the material. Canceled parathion products intended for disposal are likely
to be classified as hazardous waste. You can contact your distributor for
correct waste classification and contact your state or local hazardous waste
authority for information regarding safe disposal at a hazardous waste
facility in your area. See attached list for telephone numbers of State
agencies. For further information about the RCRA requirements for managing
parathion as a hazardous waste contact the RCRA/Superfund Industrial
Assistance Hotline at: 800 424 9346.

9. WHAT IF I POSSESS AN OPENED, PARTIALLY FILLED OR DAMAGED CONTAINER?

Any person who possesses canceled parathion product must inspect the
containers for damage. If the containers are opened, partially filled or
found in poor condition, they must have them repacked into undamaged overpack
containers. The overpack container must be immediately labeled with printed
words at least 1 inch in height that state: "Warning, this overpacked
container holds (fill in as appropriate: "Leaking," "damaged," "opened
containers," or "partial containers") of parathion. EPA registration
number:
(fill in appropriate number) . Product inside this overpacked container is
% ethyl parathion (fill in appropriate percent of parathion active
ingredient).

10. DOES EPA INTEND TO ISSUE STORAGE REQUIREMENTS FOR CANCELED PARATHION
PRODUCTS?

Because of the extreme toxicity of parathion and the dangers posed by opened.
leaking, and spilled containers, EPA intends to establish storage requirements
for canceled parathion products. EPA plans to issue proposed storage
requirements for public comment within the next several months; final storage
requirements will be published in the Federal Register after receipt and
review of these comments.

11. CAN EXISTING STOCKS OF CANCELED PRODUCTS CONTAINING PARATHION BE EXPORTED?

Once parathion technical or products containing parathion are canceled by EPA
they may only be exported to the country of origin (Denmark) and/or those
countries which permit parathion imports. The label on exported canceled
product containing parathion must contain the statements: "Not registered for
use in the United States of America" and "Not for sale in the United States of
America." Also, prior to export, the foreign purchaser must sign a statement
acknowledging that the purchaser understands that the canceled parathion
product is not registered for use in the United States and cannot be sold in
the United States. A copy of the signed purchaser statement must be
transmitted to an appropriate official of the government of the importing
country and to EPA's Office of Compliance Monitoring (EN-342), Environmental
Protection Agency, 401 M Street, S.W., Washington, DC 20460.

EPA has notified foreign governments and the United Nations International
Registry of Potentially Toxic Chemicals (IRPTC) of the cancellation of many
parathion products. The U.N. is preparing a list of countries where parathion
products may not be exported.

12. WHAT ARE THE ALTERNATIVES TO PARATHION?

Because parathion is a broad spectrum insecticide it is difficult to provide a
list of chemicals that cover all the pest/site combinations for which the
compound could be used. The major alternatives include: methyl parathion,
chlorpyrifos, dimethoate, disulfoton, azinphos-methyl, esfenvalerate and
methomyl. Consult your extension agent for pesticides and non-chemical
alternatives which can be used on your pest problem.

13. ARE THE ALTERNATIVES ANY SAFER THAN PARATHION?

Although some of the alternatives to parathion are also classified as highly
toxic and EPA is aware that there are risks to agricultural workers who are
exposed to these chemicals, the Agency considers them to pose less of a risk
to workers than parathion. None of the alternatives to parathion have caused
as many poisonings relative to the number of applications or the amount of
pesticide used. However, EPA does intend to evaluate the poisoning risks
associated with other pesticides and may initiate regulatory action at a later
date.

14. WHY IS EPA ALLOWING CONTINUED USE OF PARATHION ON FIELD CROPS?

The Agency has determined that with the increased restrictions imposed by the
agreement with the registrants, the risks to agricultural workers associated
with parathion use on field crops are lower than for most other sites.

15. WHAT RESTRICTIONS WILL APPLY FOR THE USE OF PARATHION ON FIELD CROPS?

The settlement agreement (included in its entirety in Unit III of the
Cancellation Notice) between EPA and parathion registrants imposes a number of
restrictions on the use of parathion on field crops. These restrictions
include the following:

A. Registered uses

The product may not be applied to any crop other than alfalfa, barley,
canola, cotton, sorghum, soybeans, sunflower and wheat. In the case of
canola, use is not permitted after December 31, 1991 until the required
residue data have been submitted to EPA by the registrants.

B. Application

1. Parathion can only be applied aerially and only by a certified commercial
applicator using aircraft with a closed cockpit. Groundboom and airblast
applications (by tractor or spray rig) which pose substantially greater
risks of exposure are no longer permitted.

2. Parathion may not be applied if wind speeds exceed 10 miles per hour.

3. No parathion may be applied from nozzles on fixed-wing aircraft located
more than 75 % of the distance from the center of the plane to the wing
tip. No parathion may be applied from nozzles on helicopters located
more than 75 of the distance from the center of the helicopter to the end
of the rotor.

C. Harvesting

A crop that has been treated with parathion must be harvested by
mechanical means only. No hand harvesting of crops is permitted.

D. Mixing/loading

1. In order to prevent spill or splash accidents, all mixing and loading of
the chemical must be performed in a hard-coupled, closed loading system,
with dry break couplings at all routine disconnects. Open pouring is no
longer permitted.

2. Protective clothing is required during mixing/loading including cotton or
other fabric coveralls over a long-sleeved shirt and long pants, chemical
resistant boots and gloves. When the system is pressurized, goggles or
face shields and aprons are required.

3. An observer must be present during all mixing/loading activities in order
to assist in the event of an accident. A person may not be engaged in
mixing/loading activities while acting as an observer.

E. Reentry Restrictions

After application of parathion, no person may enter or remain in the
treated area or within 100 feet of the treated area before the reentry
interval specified on the label has expired, except that persons may enter to
perform scouting or irrigation-related work in accordance with the following
requirements: (a) No entry into treated fields is permitted for the first 4
hours following application of parathion, no person shall remain in areas
under reentry restrictions for a total of more than 1 hour in any 24-hour
period, (b) before a person may enter an area where reentry is restricted, the
person must have read the product labeling or have been informed, in a
language that the person can understand, of all the requirements of the
product's labeling related to human hazards or precautions, first aid,
symptoms of poisoning, personal protective equipment specified for early
reentry, and any other labeling requirements related to safe use, and (c)
protective clothing must be worn while in treated areas and must consist of
cotton or other fabric coveralls over long-sleeved shirt and long pants
chemical resistant boots and chemical resistant gloves.

F. Buffer Zones

There must be a buffer area of 100 feet around buildings, bodies of
water, roads or adjacent boundaries where no spraying is allowed.

G. Reporting Requirements

EPA must be notified of any exposure incidents associated with the use of
the chemical. If mixing/loading or use of parathion results in worker
exposure incidents, spills, spray drift (or allegations of spray drift), or
the death of birds or other wildlife, the certified applicator and/or the
person who requested the application must telephone EPA's Parathion Help Line
1-800-382-1132 within seven days of becoming aware of the incident.

16. ARE THESE RESTRICTIONS PRACTICAL?

While these restriction are certainly extensive, EPA believes that they are
practical and are necessary in order to reduce exposure to parathion.
However, some growers may decide to use an alternate pesticide rather than
adhere to the many requirements governing the use of parathion.

17. DOES EPA INTEND TO TAKE ANY FURTHER ACTION TO RESTRICT THE USE OF
PARATHION?

EPA intends to issue a Notice of Intent to Cancel (NOIC) the field uses of
parathion in the near future. Although severe restrictions were imposed on
the use of parathion on field crops, the Agency remains concerned that these
uses still may result in unacceptable risks of exposure to agricultural
workers, to the general public through pesticide spray drift, to birds and
aquatic invertebrates (part of the food chain for fish). The Agency has
numerous reports on the effects on birds from parathion exposure to field crop
treatments.

18. IS IT SAFE TO EAT FOOD FROM CROPS TREATED WITH PARATHION?

As part of the review of this chemical, the Agency is evaluating tolerances
(allowable residues in/on treated food crops) and is asking for public comment
on whether tolerances should be revoked. The Agency's primary concern
however, is the risk of poisoning to farmworkers and birds. The Agency has no
reports of poisoning from food treated with parathion.

19. IS EPA CONSIDERING REDUCING OR REVOKING TOLERANCES?

Comments are being solicited as to what, if any, action the Agency should
initiate regarding parathion tolerances. Specifically, no action could be
taken and tolerances would be retained at current levels, all tolerances for
the food commodities related to the over 80 canceled uses could be revoked
which would prohibit the importation of these parathion-treated food
commodities into the U.S., or current tolerances could be reduce to reflect
levels on imported commodities. The Agency is also soliciting comment on the
best method to determine the appropriate levels on treated food commodities
which are imported if the tolerance reduction option is adopted. These dates
could be requested from importing countries or the Agency could rely on
monitoring data, where adequate, from the Food and Drug Administration and the
U.S. Department of Agriculture. Comments regarding tolerance reduction and/or
revocation must be submitted within 60 days of publication of this Notice to
Dennis H. Edwards Jr., Registration Division (H7505C), U. S. Environmental
Protection Agency, 401 M St. S.W., Washington, DC 20460.

NOTICE TO HOLDERS OF CANCELED PARATHION

FIFRA Section 6(g)
Reporting on the Quantity and Location of Canceled Parathion
in Your Possession

Section 6(g) of the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA)
_______________________________________________________________________

Section 6(g) of FIFRA requires certain people to notify the Environmental
Protection Agency (EPA) and appropriate State and local officials that: (1)
they possess a canceled or suspended pesticide; (2) the quantity they possess;
and (3) the location where it is stored.

NOTICE TO HOLDERS OF CANCELED PARATHION

If you have canceled parathion products, and you are a registrant, producer,
dealer, or commercial applicator, you must submit a report on the quantity and
location of the stocks you possess to the EPA and both the State Lead
Pesticide Agency and the Local Emergency Planning Commission in which the
product is located.

Who Must Report?
________________

Any producer or exporter, registrant, application for registration, applicator
or holder of an experimental use permit, commercial applicator, or any person
who distributes or sells any pesticide, and who physically possesses canceled
parathion pesticide products must report. Private applicators are not
required to report.

What Products Are Required to Be Reported?
__________________________________________

Canceled parathion products that are in your physical possession, regardless
of whether you own the product, must be reported. Products relabeled or
stickered pursuant to the cancellation order at the time the report is
submitted must not be reported, except by registrants.

Registrants possessing a product that has been relabeled or stickered, but has
not yet been reported to the EPA as relabeled or stickered pursuant to the
parathion cancellation order, must report the quantity and location of these
stocks.

What Do I Report?
_________________

1. Your name/company and address.

2. Name and phone number of a contact person (in the company).

3. A statement that the information is being submitted for canceled parathion
products.

4. Specify if you are an exporter, producer, registrant, applicant for
registration, applicant for or holder of an experimental use permit,
commercial applicator, distributor, retailer, etc., of the parathion
product.

5. The street address of each location owned, leased, or operated in the
United States by the submitter where the canceled parathion pesticide
product is held.

6. For each location, list the total quantity (pounds, gallons, or other
appropriate measure) of canceled parathion products you possess. Also list
the number of units of each size container (pound, gallon, or other
appropriate measure) by EPA registration number (e.g., x units of 5 gallon
containers of EPA registration number xxx-xxx).

7. A statement certified by a responsible company official that the
information is correct and true.

Where Do I Submit this Information?
__________________________________
The information must be sent to each of the
following locations:

(a) Director, Compliance Division, Office of Compliance Monitoring (EN-342),
U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC
20460. Envelopes must be marked: "Attention: FIFRA Section 6(9)
Information."

(b) Chief Pesticide Regulatory Official, New York State Department of
Environmental Conservation. Envelopes must be marked "Attention:
FIFRA Section 6(9) Information."

(c) Chair of the Local Emergency Planning Committee (LEPC), for the location
where the canceled parathion pesticide is stored. Envelopes must be
marked "Attention: Notification of Possession of Canceled Pesticides."
To identify the name and address of the Chair of the LEPC, contact the
State Emergency Response Commission (SERC). For the telephone number of
the SERC call the EPCRA Information Hotline at 1-800-535-0202.

When is the Deadline to Report?
_______________________________

Registrants must report this information by January 6, 1992. Producers,
exporters, applicants for a registration, applicants or holders of
experimental use permits, dealers, distributors, and retailers must report by
January 15, 1992. Commercial applicators must report by January 31, 1992.

Will this Information be Considered Confidential?
_________________________________________________

No.

What Can Happen If I Fail to Report?
____________________________________

Failure to submit complete and accurate information on the quantity and
location of canceled parathion in your possession may result in civil
penalties and/or criminal prosecution.

If I Need More Information on How to Comply With The Reporting Requirements,
Who Can I Call?
____________________________________________________________________________

You can call the Parathion Helpline at 1-800-382-1132.

What Do I Do With Leaking or Damaged Containers?
________________________________________________

Leaking, damaged, bulging, or rusted containers must be overpacked into
structurally sound and undamaged overpack drums or other DOT approved
containers within 48 hours of detection. See the cancellation order for
specific requirements.