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sulfotepp (Bladafum,Plantfum) EPA Pesticide Fact Sheet 9/88

EPA Pesticide Fact Sheet


Name of Chemical:  Sulfotepp
Reason for Issuance:  Registration Standard
Date Issued:  Sept. 30, 1988
Fact Sheet Number:  185


                       1. DESCRIPTION OF CHEMICAL

- Chemical Name:  O,O,O',O'-tetraethyl dithiopyrophosphate
  (International Union for Pure and Applied Chemistry)
- ANSI Common Name:  Not applicable
- Other Common Names:  Sulfotep (British Standards Institution and
  International Organization for Standardization); tetraethyl
  thiodiphosphate (9th Collective Index); tetraethyl thiopyrophosphate
  (8th Collective Index); thiodiphosphoric acid tetraethyl ester;
  sulfotepp (Entomological Society of America)
- Principal Trade Names:  Bladafume; Dithio; Dithione, Plantfume
- EPA Pesticide Chemical (Shaughnessy) Number:  079501
- Chemical Abstracts Service (CAS) Number:  3689-24-5
- Year of Initial Registration:  1951
- Pesticide Type(s):  Insecticide/acaricide
- Chemical Family:  Organophosphate
- U.S. Registrants:  Centerchem, Inc.; Fuller Systems, Inc.; Plant
  Products Corp.

                    2. USE PATTERNS AND FORMULATIONS

- Registered uses:  Greenhouse ornamentals (non-food crop)
- Predominant uses:  Azaleas, carnations, chrysanthemums, geraniums,
  roses, snapdragons
- Pests controlled:  Aphids, spider mites, whiteflies, mealybugs, 
scales,
  thrips
- Types of Formulations:  Ready-to-use liquid; impregnated materials
- Types and Method of Application:  Fogging with liquid spray, smoking
  with impregnated materials
- Application Rates:  1.75 fl. oz. 4.5%/5,000 ft3 (liquid fog); 1.75 oz.
  15%/5,000 ft3 (smoke generator)


                         3.  SCIENCE FINDINGS


Chemical Characteristics

- Physical state:  liquid
- Color:  pale yellow
- Odor:  Unknown
- Molecular Weight & Formula: 322.3, C8H20O5P2S2
- Boiling Point:  136-139 degrees C at 2 mm Hg
- Vapor Pressure:  1.7 x 10-4 mm Hg or 22.6 mPa at 20 degrees C
- Specific Gravity:  1.196 d25/4 degrees C, where 25 degrees  C refers 
to
  temperature at which density (d) of sulfotepp measured and 4 degrees C
  temperature at which density of H20 measured
- Solubility in various solvents:  25 mg/l water at room temperature;
  completely miscible with chloromethane and most organic solvents


Toxicology Characteristics

- Acute Oral:  Data gap.  An acute oral LD50 study in the rat is
  required.
- Acute Dermal:  Data gap.  An acute dermal LD50 study in the rabbit is
  required.
- Acute Inhalation:  Data gap.  An acute inhalation LC50 study in the
  rat is required.
- Primary Dermal Irritation:  Data gap.  A primary dermal study in the
  rabbit is required.
- Primary Eye Irritation:  Data gap.  A primary eye study in the rabbit
  is required.
- Dermal Sensitization:  Data gap.  A study in the guinea pig is
  required.
- Delayed Neurotoxicity:  Data gap.  An acute study in the hen is
  required.
- Major Routes of Exposure:  Not well understood.  Inhalation of fumes
  and dermal exposure to treated ornamentals.
- Subchronic Toxicity:  Data gaps.  A 21-day dermal study in the rabbit
  is required.  A 90-day inhalation study is required. Note: The 90-day
  feeding studies in rodent and non-rodent are not required for the
  registered use patterns.
- Oncogenicity:  Not required for the registered use patterns.
- Chronic feeding:  Not required for the registered use patterns.
- Metabolism:  Not required for the registered use patterns.
- Reproduction:  Not required for the registered use patterns.
- Teratogenicity:  Data gap.  A study in either a rodent or non-rodent
  is required.
- Mutagenicity:  Data gaps.  The gene mutation (Ames Test) and the
  chromosomal aberration studies are required, as is the test for other
  mechanisms of mutagenicity.


Physiological and Biochemical Characteristics

- Mechanism of Pesticidal Action:  Neurotoxin
- Metabolism and Persistence in Plants and Animals:  Metabolism not
  understood; short residual period on plant foliage.
- Environmental Characteristics:  There are no available environmental
  fate studies on sulfotepp.  Therefore, groundwater contamination
  potential cannot be assessed at this time.  Because of toxicological
  concerns on the acute hazards (see above), an interim ll-hour minimum
  reentry interval and 2 hours of ventilation are being imposed for the
  uses of sulfotepp until adequate data have been submitted and
  evaluated.  The following list summarizes the environmental fate data
  requirements for sulfotepp.
- Degradation Studies:  Data gaps.  Laboratory studies on hydrolysis and
  photodegradation in air are required.
- Metabolism Studies:  Data gap.  A laboratory study on aerobic soil
  metabolism is required.
- Mobility Studies:  Data gaps.  Laboratory studies on adsorption/
  desorption (batch equilibrium study preferred) and volatility are
  required.  A field volatility study is reserved until the results of
  laboratory studies are known.
- Reentry Protection:  Data gap.  An inhalation exposure study is re-
  quired.  The registrant is required to propose acceptable reentry
  labeling based upon airborne residue levels measured after observing
  the proposed label conditions, on estimated human exposure to those
  residues, and on toxicity of sulfatepp.  Because of the highly acutely
  toxic nature of sulfotepp, no actual human inhalation exposure
  monitoring data should be gathered.
- Ecological Characteristics:  No data are available for any terrestrial
  species.  The available data indicate that sulfotepp is "highly toxic"
  to the rainbow trout and bluegill sunfish.  No data are available on
  effects on freshwater invertebrates.  The following list summarizes
  the ecological effects data requirements for sulfotepp.
- Avian acute toxicity:  Data gap.  A single-dose LD50 study in the
  bobwhite quail is required.
- Avian dietary toxicity:  Data gap.  A subacute dietary LC50 study in
  the bobwhite quail is required
- Freshwater fish acute toxicity:  Rainbow trout: LC50 = 1.0 (0.8-1.3)
  ppm; bluegill sunfish: LC50 = 0.36 (0.27-0.46) ppm.  Available fish
  studies only partially fulfill the requirements, but may be upgraded
  if additional data concerning the studies are available and are
  submitted.
- Marine fish acute toxicity:  Not required for the registered use
  patterns.
- Freshwater invertebrate toxicity:  Data gap.  An acute LC50 study on
  aquatic invertebrates is required.
- Marine invertebrate toxicity:  Not required for the registered use
  patterns.


                         4.  TOLERANCE ASSESSMENT

   There are no approved tolerances for residues of sulfotepp and no 
uses on food crops.  Therefore, a tolerance assessment is not required.


                5.  SUMMARY OF REGULATORY POSITIONS

- Sulfotepp is not a candidate for Special Review at this time.
- Sulfotepp meets the criteria for restricted use classification because
  of highly acute inhalation toxicity to humans.
- Groundwater contamination concerns for sulfotepp cannot be assessed
  until basic environmental fate data requirements are met.
- An interim reentry interval based on standards proposed in Title 40,
  Code of Federal Regulations, Part 170, Subpart F, Special Standards
  for Workers in Greenhouses, Section 66, is being imposed for the uses
  of sulfotepp pending submission and evaluation of data on exposure to
  airborne residues.
- Protective clothing requirements are being imposed as labeling
  amendments for all registered sulfotepp products.


                     6.  LABELING REQUIREMENTS

   Statements applicable to all products:

     GENERAL WARNINGS AND LIMITATIONS:  Sulfotepp is classified as a
     RESTRICTED USE PESTICIDE by Title 40, Code of Federal Regulations,
     Part 162, Section 31, on the basis of its acute inhalation hazard
     to humans.


   Statements for Manufacturing-Use Products:

     ENVIRONMENTAL HAZARDS:
        This pesticide is toxic to fish.  Do not discharge effluent
     containing this product directly into lakes, streams, ponds,
     estuaries, oceans, wetlands or public waters unless this product
     is specifically identified and addressed in a NPDES permit.
     Do not discharge effluent containing this product to sewer systems
     without previously notifying the sewage treatment plant authority.
     For guidance, contact your State Water Board or Regional Office of
     the Environmental Protection Agency.


   Statements for End-Use Products:

     General Warnings and Limitations:

        Worker Protection Statement:  WEAR THE FOLLOWING PROTECTIVE
     CLOTHING DURING LOADING, APPLICATION, EQUIPMENT REPAIR, EQUIPMENT
     CLEANING, EARLY REENTRY TO TREATED AREAS, AND DISPOSAL OF THE
     PESTICIDE.  Wear a protective suit of one or two pieces that covers
     all parts of the body except the head, hands, and feet.  Wear
     chemical-resistant gloves and chemical-resistant shoes, shoe
     coverings, or boots.  Wear goggles and a pesticide respirator
     approved by the National Institute for Occupational Safety and
     Health (NIOSH) and the Mine Safety and Health Administration (MSHA)
     at all times during application and early reentry to treated areas.

     Reentry Statement:  Reentry after applying is restricted until
     one of the following intervals has elapsed:

     (l) Two hours of ventilation using fans or other mechanical
         ventilation systems.

     (2) Four hours of ventilation using vents, windows or other
         passive ventilation systems.

     (3) Eleven hours with no ventilation, followed by one hour of
         mechanical ventilation.

     (4) Eleven hours with no ventilation, followed by two hours
         of passive ventilation.

   If necessary to reenter the greenhouse for any reason during the 
specified intervals after application, protective clothing described in 
the Worker Protection Statement must be worn.  All greenhouses must be 
posted during the exposure period and until safe to reenter.

     Disposal Statement:  Pesticide wastes are acutely hazardous.
        Improper disposal of excess pesticide, spray mixture or
        rinsate is a violation of Federal Law.  If these wastes cannot
        be disposed of by use according to label instructions, contact
        your State Pesticide or Environmental Control Agency or the
        Hazardous Waste representative at the nearest EP Regional
        office for guidance.  In addition, interested parties may call
        the RCRA/Superfund Hotline toll free (1-800-424-9346) for
        information on Resource Conservation and Recovery Act
        requirements.


                      7.  SUMMARY OF DATA GAPS

   Toxicology.  All the acute toxicity studies are required, including 
the acute delayed neurotoxicity study in the hen.  The subchronic 
feeding studies in the rodent and nonrodent are not required due to lack 
of oral exposure in the registered use patterns.  The 21-day dermal and 
90-day inhalation studies are required.  The 90-day neurotoxicity study 
is reserved depending upon the results from the acute delayed neuro-
toxicity study.  A teratology study in one species is required and all 
the mutagenicity studies are required.

   Environmental Fate/Exposure.  The laboratory degradation studies on 
hydrolysis and photodegradation in air are required.  The aerobic soil 
metabolism study is required.  The laboratory mobility studies on 
adsorption/desorption (for which the batch equilibrium study is 
preferred) and volatility are required.  The field volatility study is 
reserved pending results from the laboratory studies.  The reentry 
protection study on inhalation exposure is required, but there is to be 
no actual monitoring of human inhalation exposure.

   Fish and Wildlife.  An avian single-dose acute oral LD50 study and a 
subacute dietary LC50 study using the bobwhite quail are required. 
Additional data are required on the freshwater fish toxicity study 
already submitted.  A study on the acute LC50 to aquatic invertebrates 
is required.

   Product Chemistry.  All the applicable data on product identity, 
analysis and certification of product ingredients, and physical and 
chemical properties are required.


                    8.  CONTACT PERSON AT EPA

William H. Miller
Product Manager 16
Insecticide-Rodenticide Branch
Registration Division (TS-767C)
Office of Pesticide Programs
Environmental Protection Agency
401 M St., SW
Washington, D.C.  20460

Office location and phone number:

Room 211, Crystal Mall #2
1921 Jefferson Davis Highway
Arlington, VA
(703) 557-2600


DISCLAIMER:  The information in this Pesticide Fact Sheet is a summary 
only and may not be used to satisfy data requirements for pesticide 
registration and reregistration.  The complete Registration Standard for 
the pesticide may be obtained from the contact person listed above.