**United States Prevention, Pesticides EPA 738-R-07-010**

**Environmental Protection and Toxic Substances September 12, 2008**

![](media/image1.wmf){width="1.41875in"
height="0.4979166666666667in"}**Agency (7508P)**

Reregistration

Eligibility Decision

for

Naphthalene

![](media/image2.wmf){width="6.4944444444444445in"
height="7.747916666666667in"}

**TABLE OF CONTENTS**

[**I. Introduction** 8](#__RefHeading___Toc213557882)

[**II. Chemical Overview** 8](#__RefHeading___Toc213557883)

[**A.** **Regulatory History** 8](#__RefHeading___Toc213557884)

[**B. Chemical Identification** 9](#__RefHeading___Toc213557885)

[**C. Use Profile** 9](#__RefHeading___Toc213557886)

[**D. Estimated Usage of Pesticide** 10](#__RefHeading___Toc213557887)

[**III. Summary of Naphthalene Risk Assessments**
10](#__RefHeading___Toc213557888)

[**A. Human Health Risk Assessment** 10](#__RefHeading___Toc213557889)

[**1. Toxicity of Naphthalene** 11](#__RefHeading___Toc213557890)

[**2. Carcinogenicity of Naphthalene** 16](#__RefHeading___Toc213557891)

[**3. Metabolites and Degradates** 17](#__RefHeading___Toc213557892)

[**4. Endocrine Disruption** 17](#__RefHeading___Toc213557893)

[**5. Dietary Risk (Water Only)** 17](#__RefHeading___Toc213557894)

[**6. Residential (Non-Occupational) Exposure Risk**
20](#__RefHeading___Toc213557895)

[**7. Aggregate Risk** 24](#__RefHeading___Toc213557896)

[**8. Occupational Risk** 24](#__RefHeading___Toc213557897)

[**9. Human Incident Data** 24](#__RefHeading___Toc213557898)

[**B. Environmental Risk Assessment** 25](#__RefHeading___Toc213557899)

[**1. Environmental Fate and Transport**
26](#__RefHeading___Toc213557900)

[**2.** **Terrestrial Organisms** 27](#__RefHeading___Toc213557901)

[**3. Aquatic Organisms** 31](#__RefHeading___Toc213557902)

[**IV. Risk Management, Reregistration, and Tolerance Reassessment
Decision** 34](#__RefHeading___Toc213557903)

[**A. Determination of Reregistration Eligibility**
34](#__RefHeading___Toc213557904)

[**B. Public Comment Period** 35](#__RefHeading___Toc213557905)

[**C. Regulatory Position** 36](#__RefHeading___Toc213557906)

[**1. Regulatory Rationale** 36](#__RefHeading___Toc213557907)

[**2. Endocrine Disruptor Effects** 39](#__RefHeading___Toc213557908)

[**3. Endangered Species** 40](#__RefHeading___Toc213557909)

[**D. Labeling Requirements** 40](#__RefHeading___Toc213557910)

[**V. What Registrants Need to Do** 40](#__RefHeading___Toc213557911)

[**A. Manufacturing Use Products** 40](#__RefHeading___Toc213557912)

[**1. Additional Generic Data Requirements**
40](#__RefHeading___Toc213557913)

[**2. Labeling for Manufacturing-Use Products**
41](#__RefHeading___Toc213557914)

[**B. End-Use Products** 41](#__RefHeading___Toc213557915)

[**1. Additional Product-Specific Data Requirements**
41](#__RefHeading___Toc213557916)

[**2. Labeling for End-Use Products** 41](#__RefHeading___Toc213557917)

[**C. Labeling Changes Summary Table** 42](#__RefHeading___Toc213557918)

[**Appendix A. Use Patterns Eligible for Reregistration for
Naphthalene** 46](#__RefHeading___Toc213557919)

[**Appendix B**](#__RefHeading___Toc213557920). [**Data Supporting
Guideline Requirements for the Reregistration of Naphthalene**
47](#__RefHeading___Toc213557921)

[**Appendix C. Technical Support Documents**
49](#__RefHeading___Toc213557922)

[**Appendix D. Citations Considered to be Part of the Database
Supporting the Reregistration Decision (Bibliography)**
50](#__RefHeading___Toc213557923)

**Glossary of Terms and Abbreviations**

ai Active Ingredient

CFR Code of Federal Regulations

DCI Data Call-In

EC Emulsifiable Concentrate Formulation

EDSTAC Endocrine Disruptor Screening and Testing Advisory Committee

EEC Estimated Environmental Concentration

EPA Environmental Protection Agency

EUP End-Use Product

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FIRST FQPA Index Reservoir Screening Tool

FFDCA Federal Food, Drug, and Cosmetic Act

GLN Guideline Number

HED Health Effects Division

HDT Highest Dose Tested

IRIS Integrated Risk Information System

LADD Lifetime Average Daily Dose

LC~50~ Median Lethal Concentration. A statistically derived
concentration of a substance that can be expected to cause death in 50%
of test animals. It is usually expressed as the weight of substance per
weight or volume of water, air or feed, e.g., mg/l, mg/kg or ppm.

LD~50~ Median Lethal Dose. A statistically derived single dose that can
be expected to cause death in 50% of the test animals when administered
by the route indicated (oral, dermal, inhalation). It is expressed as a
weight of substance per unit weight of animal, e.g., mg/kg.

LOC Level of Concern

LOAEL Lowest Observed Adverse Effect Level

mg/kg/day Milligram Per Kilogram Per Day

mg/L Milligrams Per Liter

µmol Millimoles Per Liter

MOA Mode of Action

MOE Margin of Exposure

MRID Master Record Identification (number). EPA\'s system of recording
and tracking studies submitted.

MUP Manufacturing-Use Product

N/A Not Applicable

NAWQA National Water-Quality Assessment Program

NCEA National Center for Environmental Assessment

NDETF Non-Dietary Exposure Task Force

NLAA Not Likely to Adversely Affect

NR Not Required

NOAEL No Observed Adverse Effect Level

NTP National Toxicology Program

OPP EPA Office of Pesticide Programs

OPPTS EPA Office of Prevention, Pesticides and Toxic Substances

PCC Poison Control Center

PII Primary Irritation Index

PK Pharmacokinetic

ppb Parts Per Billion

POD Point of Departure

ppm Parts per Million

RED Reregistration Eligibility Decision

REI Restricted Entry Interval

RfC Reference Concentration

RfD Reference Dose

SCI-GROW Screening Concentration In Ground Water

SF Safety Factor

TREX Terrestrial Residue Exposure (T-REX)

USDA United States Department of Agriculture

USGA US Geological Survey

UF Uncertainty Factor

UF~db~ Database Uncertainty Factor

**NAPHTHALENE TEAM**

**Office of Pesticide Programs:**

[Health Effects Risk Assessment]{.underline}

Wade Britton

Danette Drew

John Liccione, Ph.D.

[Ecological Fate and Effects Risk Assessment]{.underline}

Stephen Carey

Mark Corbin

[Biological and Economics Analysis Assessment]{.underline}

Rafael Prieto

Steve Jarboe

LaVerne Dobbins

[Registration Division]{.underline}

Dan Peacock

John Hebert

[Risk Management]{.underline}

Molly Clayton

Kevin Costello

**Abstract**

The Environmental Protection Agency (EPA or the Agency) has completed
the human health and ecological risk assessments for naphthalene and is
issuing its risk management decision. The human health and ecological
risk assessments, which are summarized below, are based on the review of
the required target database supporting the use patterns of currently
registered products. As a result of this review, EPA has determined that
naphthalene-containing products are eligible for reregistration,
provided that risk mitigation measures described in this document are
adopted and labels are amended accordingly. That decision is discussed
fully in this document.

Naphthalene is an insecticide; the majority of its pesticidal use is as
a moth repellant to protect garments from insect damage (indoor) and as
an animal repellant against nuisance vertebrate pests (indoor and
outdoor). There are no food uses, and all registered products of
naphthalene are intended for residential uses only. The indoor products
are formulated as mothballs or flakes, while outdoor products are
formulated as flakes or granules. Of the risk scenarios assessed, only
the risk from episodic ingestion of mothballs by toddlers was of
concern. Mitigation measures, including special packaging and
precautionary label language, will be required to address this potential
risk of concern.

[]{#__RefHeading___Toc213557882 .anchor}**I. Introduction**

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was
amended in 1988 to accelerate the reregistration of products with active
ingredients registered prior to November 1, 1984. The amended Act calls
for the development and submission of data to support the reregistration
of an active ingredient, as well as a review of all submitted data by
the U.S. Environmental Protection Agency (referred to as EPA or "the
Agency"). Reregistration involves a thorough review of the scientific
database underlying a pesticide's registration. The purpose of the
Agency's review is to reassess the potential risks arising from the
currently registered uses of the pesticide, to determine the need for
additional data on health and environmental effects, and to determine
whether or not the pesticide meets the "no unreasonable adverse effects"
criterion of FIFRA.

This document summarizes EPA's human health and ecological risk
assessments and reregistration eligibility decision (RED) for
naphthalene. The document consists of six sections. Section I contains
the regulatory framework for reregistration; Section II provides an
overview of the chemical and a profile of its use and usage; Section III
gives an overview of the human health and ecological risk assessments;
Section IV presents the Agency\'s decision on reregistration eligibility
and risk management; and Section V summarizes the label changes
necessary to implement the risk mitigation measures outlined in Section
IV. Finally, the Appendices list related information, supporting
documents, and studies evaluated for the reregistration decision. The
risk assessments for naphthalene and all other supporting documents are
available in the Office of Pesticide Programs (OPP) public docket
(http://www.regulations.gov) under docket number EPA-HQ-OPP-2008-0343.

[]{#__RefHeading___Toc213557883 .anchor}**II. Chemical Overview**

A.  []{#__RefHeading___Toc213557884 .anchor}**Regulatory History**

    []{.mark}

The Agency's predecessor for pesticide registrations, the U.S.
Department of Agriculture (USDA), first registered a product containing
naphthalene in 1948. The Agency issued a Registration Standard for this
active ingredient in 1981 and required submission or citation of the
following data: chemistry; environmental fate and effects; acute,
subchronic, chronic human health effects; and efficacy data. In the
latter half of the 1990s, the Agency initiated a Label Improvement
Program (LIP) to update the precautionary text, use directions, storage,
and disposal instructions to reduce exposure to naphthalene, especially
when used in homes.

Currently, there are 9 registered naphthalene products. One is a
manufacturing-use product and 8 are end-use products. All are registered
under Section 3 of FIFRA. There are no Special Local Need (SLN)
registrations under Section 24(c) of FIFRA. The Agency has registered
products for domestic, indoor use to kill moths inside of airtight
spaces (closets, chests, and garment bags) and to repel bats, tree
squirrels, and birds from attics and wall voids. There are naphthalene
products for domestic, outdoor use to repel rabbits, snakes, Norway
rats, roof rats, and house mice.

[]{#__RefHeading___Toc213557885 .anchor}**B. Chemical Identification**

**NAPHTHALENE:**

![](media/image3.png){width="6.0in" height="4.802083333333333in"}

Naphthalene is a white, crystalline solid with a characteristic odor.

Common Name: Naphthalene

Chemical Class: Insecticide

PC Code: 055801

Case Number: 0022

CAS Registry Number: 91-20-3

Molecular Weight: 128.18 g/mole

Empirical Formula: Number range CHAPTERC~10~H~8~

Technical Registrants: Reochem, Inc.

[]{#__RefHeading___Toc213557886 .anchor}**C. Use Profile**

The following information on the currently registered uses includes an
overview of use sites and application methods. A detailed table of the
uses of naphthalene eligible for reregistration is contained in Appendix
A.

**Type of Pesticide:** Insecticide and repellant.

**Target Organism:** The primary target pests are moths and nuisance
vertebrate pests (squirrels, rats, rabbits, bats, etc).

**Use Sites:** Naphthalene is registered for use on indoor and outdoor
residential use sites. It is used indoors as a moth repellant, and
placed in closed drawers, closets, and other storage areas. It is also
used in attics as a squirrel and bat repellant. Outdoors, it is used
around garden and building peripheries to repel animals such as snakes
and rabbits.

**Use Classification:** Naphthalene products are designated as general
use.

**Formulation Types:** Balls**,** granules, and flakes.

**Application Methods:** By hand.

**Application Rates:** Actual application rates for naphthalene products
are imprecise, based on formulation type and application method. It is
registered for use on indoor sites as a moth repellant in mothballs and
flakes at rates ranging from 0.25 pounds of active ingredient per 12
cubic feet (0.25 lb ai/12 ft^3^) to 0.37 lb ai/12 ft^3^. When used
indoors as an animal repellant, it is formulated as a flake and applied
at a rate of 1 lb ai/400 ft^3^ (or 1 oz/3 ft^3^ for smaller spaces).
When used outdoors and formulated as granules or flakes, it is applied
at rates ranging from 0.56 lb ai/treated area to 10.8 lb ai/treated
area.

**Application Timing:** Registered labels for indoor moth treatment use
recommend keeping the product in an airtight space for a minimum of
seven days. Re-treatment is recommended when the mothballs have
dissipated. Since moths are active all year, there is the potential for
continual treatment indoors. One moth control label recommends
re-treatment twice per year. Re-treatment for indoor/outdoor repellant
uses is recommended as needed to maintain odor intensity. Hot weather,
wind, and rain may diminish the effectiveness of the product and
necessitate re-treatment.

[]{#__RefHeading___Toc213557887 .anchor}**D. Estimated Usage of
Pesticide**

Approximately 7.5 million lbs of naphthalene are marketed on average per
year as a pesticide. The vast majority of the usage is in indoor moth
repellant products.

Pesticide usage accounts for a small portion of total US naphthalene
exposure. More than 90% of total naphthalene usage comes from other
sources. Naphthalene is produced as a naturally occurring constituent of
fossil fuels (*i.e.*, petroleum and coal) as well as a byproduct of
combustion of organic matter (*e.g.*, it is generated by burning wood).
Approximately 369 million lbs. of naphthalene is consumed by the
Department of Defense annually, and 1.84 billion lbs. of naphthalene is
consumed in the US jet fuel market.

[]{#__RefHeading___Toc213557888 .anchor}**III. Summary of Naphthalene
Risk Assessments**

The following is a summary of EPA's revised human health and ecological
risk assessments for naphthalene, as presented fully in the documents,
*Phase 4 Amendment: Response to Comments in Reference to "Naphthalene:
HED Chapter for the Reregistration Eligibility Decision Document (RED)*"
dated August 22, 2008 and *Revised Ecological Risk Assessment for
Reregistration Eligibility Decision (RED) for Naphthalene,* dated April
21, 2008. These documents are available in the OPP Public Docket, docket
number EPA-HQ-OPP-2008-0343, and may also be accessed through the
Agency's website at
[https://www.regulations.gov](https://www.regulations.gov/). The purpose
of the following summary is to assist the reader by identifying the key
features and findings of the naphthalene human health and ecological
risk assessments, and to help the reader better understand the
conclusions reached in the assessments.

EPA's use of human studies in the naphthalene risk assessment is in
accordance with the Agency's Final Rule promulgated on January 26, 2006,
related to Protections for Subjects in Human Research, which is codified
in 40 CFR Part 26.

[]{#__RefHeading___Toc213557889 .anchor}**A. Human Health Risk
Assessment**

The human health risk assessment incorporates potential exposure,
hazard, and risks from all sources, which for naphthalene are indoor and
outdoor residential use. Naphthalene has no registered food or
occupational uses. The Agency's human health assessment considers all
U.S. populations, including infants and young children. For more
information on the naphthalene human health risk assessments, see *Phase
4 Amendment: Response to Comments in Reference to "Naphthalene: HED
Chapter for the Reregistration Eligibility Decision Document (RED)*"
dated August 22, 2008, and *Naphthalene: Phase 4 Amendment: Response to
Comments In Reference to "Naphthalene: Occupational and Residential
Exposure Assessment and Recommendations for the Reregistration
Eligibility Decision Document*", dated August 8, 2008.

[]{#__RefHeading___Toc213557890 .anchor}. **1. Toxicity of Naphthalene**

Toxicity assessments are designed to predict whether a pesticide could
cause adverse health effects in humans (including short-term or acute
effects, such as skin or eye damage, and lifetime or chronic effects,
such as cancer, developmental effects, or reproductive effects), and the
level or dose at which such effects might occur. The Agency has reviewed
all toxicity studies submitted for naphthalene.

**a. Acute Toxicity Profile**

Naphthalene is considered slightly toxic on an acute basis by the oral
and dermal routes (Toxicity Category III). It is considered to be
moderately toxic by the inhalation route (Toxicity Category II). It is
categorized also as slightly toxic for primary eye and skin irritation
(Toxicity Category III). Naphthalene did not induce delayed contact
sensitivity (dermal sensitization) when tested in guinea pigs. The acute
toxicity profile for naphthalene is summarized in Table 1 below.

+-------+-----------------+----------+-----------------------+--------+
| **Tab |                 |          |                       |        |
| le 1. |                 |          |                       |        |
| Acute |                 |          |                       |        |
| Tox   |                 |          |                       |        |
| icity |                 |          |                       |        |
| Pr    |                 |          |                       |        |
| ofile |                 |          |                       |        |
| for   |                 |          |                       |        |
| Nap   |                 |          |                       |        |
| hthal |                 |          |                       |        |
| ene** |                 |          |                       |        |
+=======+=================+==========+=======================+========+
| **G   | **Study Type**  | **Master | **Results**           | **Toxi |
| uidel |                 | Record   |                       | city** |
| ine** |                 | Identi   |                       |        |
|       |                 | fication |                       | **C    |
|       |                 | (MRID)** |                       | ategor |
|       |                 |          |                       | y^a^** |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Acute Oral -    | 257224   | LD~50~: 2649 mg/kg    | III    |
| .1100 | rat             |          | (♂+♀)                 |        |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Acute Dermal    | 257229   | LD~50~ \>2000 mg/kg   | III    |
| .1200 |                 |          | (♂+♀)                 |        |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Acute           | 257902   | LC~50~ \> 0.4 mg/L    | II     |
| .1300 | Inhalation      |          | (77.7 ppm) (♂+♀)      |        |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Primary Eye     | 257228   | Slight-moderate       | III    |
| .2400 | Irritation      |          | irritation            |        |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Primary Skin    | 257227   | Moderate irritation   | III    |
| .2500 | Irritation      |          |                       |        |
+-------+-----------------+----------+-----------------------+--------+
| 870   | Dermal          | 00148173 | Nonsensitizer --      | N/A    |
| .2600 | Sensitization   |          | guinea pig            |        |
+-------+-----------------+----------+-----------------------+--------+

a.  These technical acute toxicity values included in this document are
    for informational purposes only. The data supporting these values
    may or may not meet the current acceptance criteria.

```{=html}
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```
b.  **Toxicological Endpoints**

Based on the use pattern, the standard toxicology database for
naphthalene is complete for assessing dermal and oral exposure risks to
humans. There is no reproductive study on naphthalene, nor is one
required since this is a nonfood use pesticide.

Naphthalene inhalation studies include nose-only, *i.e.* compound
introduced directly to the nose (4-week, 13-week, and subchronic 90-day
neurotoxicity) and chamber studies (2 year) in rodents, which involves
whole body exposures. These studies indicate that naphthalene is a nasal
toxicant in rodents at low experimental concentrations. Although
standard inhalation rodent toxicity studies are available, some
mechanism studies have raised the issue of notable species differences
(in regard to respiratory toxicity and metabolism) and the applicability
of the rodent model as a default approach to estimate human risk
following inhalation exposures. There is support from published studies
and ongoing research on naphthalene that indicate that risk estimates
would be considerably less than those using default procedures when
known species differences between rodents and primates (including
humans) in metabolism and respiratory toxicity are factored into the
estimates. The mechanism data are not yet complete and ongoing research,
when completed, is expected to significantly refine the potential
toxicity hazard associated with human exposure to naphthalene via
inhalation. At this time, dose range and endpoints have been
qualitatively characterized for the purposes of estimating human
inhalation (cancer and non-cancer) risk. See *Phase 4 Amendment:
Response to Comments in Reference to "Naphthalene: HED Chapter for the
Reregistration Eligibility Decision Document (RED)*" dated August 22,
2008 for additional information.

Subchronic oral toxicity of naphthalene is manifested by body weight
changes, organ weight changes and/or clinical signs of toxicity
following gavage treatment to rats. In a 90-day dermal toxicity study in
the rat, effects were noted only at the high dose of 1000 mg/kg/day.
Because effects were seen only at the limit dose, dermal toxicity is not
likely a concern. There was no evidence of developmental toxicity in the
rat or rabbit. The toxicological endpoints used in the human health risk
assessment for naphthalene are listed in Table 2 below.

To estimate residential (dermal and incidental oral) risk, the Agency
calculates a margin of exposure (MOE), which is the ratio of the point
of departure (POD) selected for risk assessment to the exposure. The POD
is typically a No Observed Adverse Effects Level (NOAEL) or a Lowest
Observed Adverse Effects Level (LOAEL). This MOE is compared to a level
of concern (LOC), which is the same value as the uncertainty factor (UF)
applied to a particular toxicity study. In the case of the naphthalene
risk assessment for acute dietary exposure, the endpoint selected
occurred following a single exposure and is relevant for all
populations, including infants and children. A UF of 1000 was applied to
account for the use of a LOAEL because there is no NOAEL (10X), in
addition to the standard uncertainty factors (UF) of 10X for
intraspecies extrapolation and 10X for interspecies variation.

For chronic oral exposure, an UF of 10X has been applied to the chronic
RfD to account for extrapolation from subchronic to chronic oral
exposure, in addition to the 100-fold uncertainty factor applied to
account for inter and intraspecies differences. The composite
uncertainty factor of 1000-fold would address the lack of reproductive
toxicity data. The target MOE (*i.e.*, level of concern) for incidental
oral and dermal exposures is 100 (10X for intraspecies extrapolation and
10X for interspecies variation).

+----------+----------+-----------+-----------+----------------------+
| **Table  |          |           |           |                      |
| 2.       |          |           |           |                      |
| Toxic    |          |           |           |                      |
| ological |          |           |           |                      |
| Doses    |          |           |           |                      |
| and      |          |           |           |                      |
| E        |          |           |           |                      |
| ndpoints |          |           |           |                      |
| for      |          |           |           |                      |
| Nap      |          |           |           |                      |
| hthalene |          |           |           |                      |
| for Use  |          |           |           |                      |
| in Human |          |           |           |                      |
| Health   |          |           |           |                      |
| Risk     |          |           |           |                      |
| Asses    |          |           |           |                      |
| sments** |          |           |           |                      |
+==========+==========+===========+===========+======================+
| **Exp    | **Point  | **Un      | **Level   | **Study, MRID, and   |
| osure/** | of       | certainty | of        | Toxicological        |
|          | D        | Factors   | Concern   | Effects**            |
| **Sc     | eparture | (UF)**    | for Risk  |                      |
| enario** | (POD)**  |           | A         |                      |
|          |          |           | ssessment |                      |
|          |          |           | (LOC)**   |                      |
+----------+----------+-----------+-----------+----------------------+
| Acute    | LOAEL =  | UF~A~=    | aRfD=0.4  | **Acute Oral         |
| Dietary  | 400      | 10X       | mg/kg/day | Neurotoxicity Study  |
|          | m        |           |           | -- Rat** (44282801)  |
| [All     | g/kg/day | UF~H~ =   |           |                      |
| populati |          | 10X       |           | NOAEL = not          |
| ons]{.un |          |           |           | identified.          |
| derline} |          | UF~L~=    |           |                      |
| i        |          | 10X       |           | LOAEL = 400          |
| ncluding |          |           |           | mg/kg/day based on   |
| infants  |          |           |           | hunched posture in   |
| and      |          |           |           | females, head        |
| children |          |           |           | shaking in males and |
|          |          |           |           | females, and reduced |
|          |          |           |           | motor activity in    |
|          |          |           |           | males and females.   |
+----------+----------+-----------+-----------+----------------------+
| Chronic  | NOAEL=   | UF~A~=    | cRfD =    | **National           |
| Dietary  | 100      | 10X       | 0.1       | Toxicology Program   |
|          | m        |           | mg/kg/day | (NTP) Subchronic Rat |
| [All     | g/kg/day | UF~H~ =   |           | Study** (NTP 1980a)  |
| populati |          | 10X       |           |                      |
| ons]{.un |          |           |           | NOAEL = 100          |
| derline} |          | UF~S~ =   |           | mg/kg/day            |
| i        |          | 10X       |           |                      |
| ncluding |          |           |           | LOAEL = 200          |
| infants  |          |           |           | mg/kg/day based on   |
| and      |          |           |           | significant          |
| children |          |           |           | decreases in body    |
|          |          |           |           | weights/body weight  |
|          |          |           |           | gains.               |
+----------+----------+-----------+-----------+----------------------+
| Episodic | NOAEL=   | UF~A~=    | MOE= 100  | **NTP Developmental  |
| I        | 50       | 10X       |           | Rat Study** (NTP     |
| ngestion |          |           | (res      | 1991)                |
| (Sho     | m        | UF~H~=    | idential) |                      |
| rt-term; | g/kg/day | 10X       |           | NOAEL = 50 mg/kg/day |
| 1-30     |          |           |           |                      |
| days)    |          |           |           | LOAEL= 150 mg/kg/day |
|          |          |           |           | based on maternal    |
|          |          |           |           | effects --transient  |
|          |          |           |           | clinical signs of    |
|          |          |           |           | lethargy and slow    |
|          |          |           |           | breathing, and       |
|          |          |           |           | significant          |
|          |          |           |           | decreases in body    |
|          |          |           |           | weights/body weight  |
|          |          |           |           | gains and decreased  |
|          |          |           |           | food and water       |
|          |          |           |           | consumption.         |
+----------+----------+-----------+-----------+----------------------+
| Dermal   | Dermal   | UF~A~=    | MOE= 100  | **90-Day Dermal      |
| (Sho     | NOAEL=   | 10X       |           | Toxicity Study       |
| rt-Term; | 300      |           | (res      | --Rat** (40021801)   |
| 1-30     | m        | UF~H~=    | idential) |                      |
| days)    | g/kg/day | 10X       |           | NOAEL = 300          |
|          |          |           |           | mg/kg/day            |
|          |          |           |           |                      |
|          |          |           |           | LOAEL = 1000         |
|          |          |           |           | mg/kg/day based on   |
|          |          |           |           | atrophy of           |
|          |          |           |           | seminiferous tubules |
|          |          |           |           | in males, and        |
|          |          |           |           | nonneoplastic        |
|          |          |           |           | lesions in the       |
|          |          |           |           | cervical lymph node  |
|          |          |           |           | (hyperplasia), liver |
|          |          |           |           | (hemosiderosis),     |
|          |          |           |           | thyroid thyroglossal |
|          |          |           |           | duct cysts, kidneys  |
|          |          |           |           | (pyelonephritis),    |
|          |          |           |           | urinary bladder      |
|          |          |           |           | (hyperplasia) and    |
|          |          |           |           | skin (acanthosis,    |
|          |          |           |           | hyperkeratosis) in   |
|          |          |           |           | females.             |
+----------+----------+-----------+-----------+----------------------+
| In       | In       | N/A       | N/A       | **4-Week (Nose-Only) |
| halation | halation |           |           | Inhalation -- Rat**  |
| (Sho     |          |           |           | (42934901)           |
| rt-term; | LOAEL    |           |           |                      |
| 1-30     |          |           |           | NOAEL = 3 ppm        |
| days)    | = 10 ppm |           |           |                      |
|          | or       |           |           | LOAEL = 10 ppm based |
|          |          |           |           | increased incidence  |
|          | 52       |           |           | and severity of      |
|          | mg/m^3^  |           |           | nasal lesions        |
|          |          |           |           | (slight              |
|          | NOAEL    |           |           | disorganization,     |
|          |          |           |           | rosette formation,   |
|          | = 3 ppm  |           |           | basal cell           |
|          | or       |           |           | hyperplasia,         |
|          |          |           |           | erosion, atrophy,    |
|          | 16       |           |           | and degenerate cells |
|          | mg/m^3^  |           |           | in the olfactory     |
|          |          |           |           | epithelium; loss of  |
|          |          |           |           | bowman's glands;     |
|          |          |           |           | respiratory          |
|          |          |           |           | epithelium           |
|          |          |           |           | hypertrophy; rosette |
|          |          |           |           | formation in the     |
|          |          |           |           | septal organ of      |
|          |          |           |           | Masera and fusion of |
|          |          |           |           | the turbinates).     |
+----------+----------+-----------+-----------+----------------------+
| In       | In       | N/A       | N/A       | **13-Week            |
| halation | halation |           |           | (nose-only)          |
| (In      |          |           |           | Inhalation Rat       |
| termedia | LOAEL    |           |           | Study**              |
| te-term; |          |           |           | (44956401)**;        |
| 1-6      | = 2 ppm  |           |           | Subchronic           |
| months)  | or       |           |           | (nose-only)          |
|          |          |           |           | Neurotoxicity Rat    |
|          | 10       |           |           | Study** (44856401)   |
|          | mg/m^3^  |           |           |                      |
|          |          |           |           | NOAEL = 1 ppm        |
|          | NOAEL    |           |           | (Subchronic          |
|          |          |           |           | neurotoxicity study) |
|          | = 1 ppm  |           |           |                      |
|          | or       |           |           | NOAEL (13 week       |
|          |          |           |           | inhalation study) -- |
|          | 5.2      |           |           | not identified.      |
|          | mg/m^3^  |           |           |                      |
|          |          |           |           | LOAEL = 2 ppm (13    |
|          |          |           |           | week inhalation      |
|          |          |           |           | study) based on      |
|          |          |           |           | increased incidence  |
|          |          |           |           | and severity of      |
|          |          |           |           | nasal lesions        |
|          |          |           |           | (degeneration,       |
|          |          |           |           | atrophy and          |
|          |          |           |           | hyperplasia of basal |
|          |          |           |           | cells of the         |
|          |          |           |           | olfactory            |
|          |          |           |           | epithelium; rosette  |
|          |          |           |           | formation of         |
|          |          |           |           | olfactory            |
|          |          |           |           | epithelium; loss of  |
|          |          |           |           | Bowman's glands;     |
|          |          |           |           | hypertrophy of       |
|          |          |           |           | respiratory          |
|          |          |           |           | epithelium).         |
|          |          |           |           |                      |
|          |          |           |           | LOAEL = 10 ppm       |
|          |          |           |           | (subchronic          |
|          |          |           |           | neurotoxicity study) |
|          |          |           |           | based on             |
|          |          |           |           | atr                  |
|          |          |           |           | ophy/disorganization |
|          |          |           |           | of the olfactory     |
|          |          |           |           | epithelium and       |
|          |          |           |           | hyperplasia of the   |
|          |          |           |           | respiratory and      |
|          |          |           |           | transitional         |
|          |          |           |           | epithelium.          |
+----------+----------+-----------+-----------+----------------------+
| In       | In       | N/A       | N/A       | **NTP                |
| halation | halation |           |           | ChronicToxicity and  |
| (Lo      | LOAEL    |           |           | Carcinogenicity      |
| ng-term; |          |           |           | Studies in the Rat   |
| \> 6     | = 10 ppm |           |           | and Mouse** (NTP     |
| months)  | or       |           |           | 1992)                |
|          |          |           |           |                      |
|          | 52       |           |           | NOAEL = not          |
|          | mg/m^3^  |           |           | identified           |
|          |          |           |           |                      |
|          |          |           |           | LOAEL (rat study) =  |
|          |          |           |           | 10 ppm based on      |
|          |          |           |           | increased incidence  |
|          |          |           |           | and severity of      |
|          |          |           |           | atypical (basal      |
|          |          |           |           | cell) hyperplasia,   |
|          |          |           |           | atrophy, chronic     |
|          |          |           |           | inflammation, and    |
|          |          |           |           | hyaline degeneration |
|          |          |           |           | of the olfactory     |
|          |          |           |           | epithelium;          |
|          |          |           |           | hyperplasia,         |
|          |          |           |           | squamous metaplasia, |
|          |          |           |           | hyaline              |
|          |          |           |           | degeneration, and    |
|          |          |           |           | goblet cell          |
|          |          |           |           | hyperplasia of the   |
|          |          |           |           | respiratory          |
|          |          |           |           | epithelium; and      |
|          |          |           |           | glandular            |
|          |          |           |           | hyperplasia and      |
|          |          |           |           | squamous metaplasia. |
+----------+----------+-----------+-----------+----------------------+
| Point of |          |           |           |                      |
| D        |          |           |           |                      |
| eparture |          |           |           |                      |
| (POD) =  |          |           |           |                      |
| A data   |          |           |           |                      |
| point or |          |           |           |                      |
| an       |          |           |           |                      |
| e        |          |           |           |                      |
| stimated |          |           |           |                      |
| point    |          |           |           |                      |
| that is  |          |           |           |                      |
| derived  |          |           |           |                      |
| from     |          |           |           |                      |
| observed |          |           |           |                      |
| dose-    |          |           |           |                      |
| response |          |           |           |                      |
| data and |          |           |           |                      |
| used to  |          |           |           |                      |
| mark the |          |           |           |                      |
| b        |          |           |           |                      |
| eginning |          |           |           |                      |
| of       |          |           |           |                      |
| extra    |          |           |           |                      |
| polation |          |           |           |                      |
| to       |          |           |           |                      |
| d        |          |           |           |                      |
| etermine |          |           |           |                      |
| risk     |          |           |           |                      |
| as       |          |           |           |                      |
| sociated |          |           |           |                      |
| with     |          |           |           |                      |
| lower    |          |           |           |                      |
| environ  |          |           |           |                      |
| mentally |          |           |           |                      |
| relevant |          |           |           |                      |
| human    |          |           |           |                      |
| ex       |          |           |           |                      |
| posures. |          |           |           |                      |
| NOAEL =  |          |           |           |                      |
| no       |          |           |           |                      |
| observed |          |           |           |                      |
| adverse  |          |           |           |                      |
| effect   |          |           |           |                      |
| level.   |          |           |           |                      |
| LOAEL =  |          |           |           |                      |
| lowest   |          |           |           |                      |
| observed |          |           |           |                      |
| adverse  |          |           |           |                      |
| effect   |          |           |           |                      |
| level.   |          |           |           |                      |
| UF =     |          |           |           |                      |
| unc      |          |           |           |                      |
| ertainty |          |           |           |                      |
| factor.  |          |           |           |                      |
| UF~A~ =  |          |           |           |                      |
| extra    |          |           |           |                      |
| polation |          |           |           |                      |
| from     |          |           |           |                      |
| animal   |          |           |           |                      |
| to human |          |           |           |                      |
| (inters  |          |           |           |                      |
| pecies). |          |           |           |                      |
| UF~H~ =  |          |           |           |                      |
| p        |          |           |           |                      |
| otential |          |           |           |                      |
| v        |          |           |           |                      |
| ariation |          |           |           |                      |
| in       |          |           |           |                      |
| sen      |          |           |           |                      |
| sitivity |          |           |           |                      |
| among    |          |           |           |                      |
| members  |          |           |           |                      |
| of the   |          |           |           |                      |
| human    |          |           |           |                      |
| po       |          |           |           |                      |
| pulation |          |           |           |                      |
| (intras  |          |           |           |                      |
| pecies). |          |           |           |                      |
| UF~L~ =  |          |           |           |                      |
| use of a |          |           |           |                      |
| LOAEL to |          |           |           |                      |
| ext      |          |           |           |                      |
| rapolate |          |           |           |                      |
| a NOAEL. |          |           |           |                      |
| UF~S\ =~ |          |           |           |                      |
| use of a |          |           |           |                      |
| sh       |          |           |           |                      |
| ort-term |          |           |           |                      |
| study    |          |           |           |                      |
| for      |          |           |           |                      |
| l        |          |           |           |                      |
| ong-term |          |           |           |                      |
| risk     |          |           |           |                      |
| ass      |          |           |           |                      |
| essment. |          |           |           |                      |
| UF~DB~ = |          |           |           |                      |
| to       |          |           |           |                      |
| account  |          |           |           |                      |
| for the  |          |           |           |                      |
| absence  |          |           |           |                      |
| of key   |          |           |           |                      |
| date     |          |           |           |                      |
| (*i.e.*, |          |           |           |                      |
| lack of  |          |           |           |                      |
| a        |          |           |           |                      |
| critical |          |           |           |                      |
| study).  |          |           |           |                      |
| RfD =    |          |           |           |                      |
| r        |          |           |           |                      |
| eference |          |           |           |                      |
| dose.    |          |           |           |                      |
| MOE =    |          |           |           |                      |
| margin   |          |           |           |                      |
| of       |          |           |           |                      |
| e        |          |           |           |                      |
| xposure. |          |           |           |                      |
| LOC =    |          |           |           |                      |
| level of |          |           |           |                      |
| concern. |          |           |           |                      |
| N/A =    |          |           |           |                      |
| not      |          |           |           |                      |
| app      |          |           |           |                      |
| licable. |          |           |           |                      |
+----------+----------+-----------+-----------+----------------------+

[]{#__RefHeading___Toc213557891 .anchor}**2. Carcinogenicity of
Naphthalene**

In the National Toxicology Program (NTP) chronic studies, carcinogenic
effects have been observed in both rats and mice following inhalation
exposure to naphthalene. In the rat, nasal tumors included
neuroblastomas of the olfactory epithelium and adenomas of the
respiratory epithelium. There was also an increase in the incidences of
adenoma of the respiratory epithelium. The NTP concluded that "under the
conditions of this 2-year inhalation study, there was clear evidence of
carcinogenic activity of naphthalene in male and female F344/N rats
based on increased incidences of respiratory epithelial adenoma and
olfactory epithelial neuroblastoma of the nose."

In the mouse study, male mice had statistically significant increased
incidences of liver adenomas, and adenomas and carcinomas combined.
Female mice exhibited increased incidences of alveolar/bronchiolar
adenomas, and adenomas and carcinomas combined. The NTP concluded that
"under the conditions of this 2-year inhalation study, there was no
evidence of carcinogenic activity' of naphthalene in male B6C3F1 mice
exposed to 10 or 30 ppm. There was "some evidence of carcinogenic
activity" of naphthalene in female B6C3F1 mice, based on increased
incidences of pulmonary alveolar/bronchiolar adenomas.

The carcinogenic and noncarcinogenic potential of naphthalene is
currently undergoing review by the EPA Integrated Risk Information
System (IRIS). The EPA process of regulating pesticides allows for
re-evaluation at any time if relevant new information becomes available.
Thus, when the IRIS assessment is finalized, OPP would determine whether
the human health hazard potential of naphthalene warrants revisiting.

[]{#__RefHeading___Toc213557892 .anchor}**3. Metabolites and
Degradates**

A number of degradates were identified in the open literature. A
degradation pathway for naphthalene was proposed, which ultimately
resulted in catechol. Transitional degradates included
cis-1,2-dihydroxy-1,2-dihydronaphthalene, 1,2-dihydroxy-naphthalene,
2-hydroxchromene-2-carboxylate (HCCA),
trans-o-hydroxy-benzylidenpyruvate (tHBPA), salicyladehyde, and
salicylate. However, there are no environmental fate data for these
degradates, and therefore, exposure estimates are for parent only. For
additional details, refer to the *Revised Ecological Risk Assessment for
Reregistration Eligibility Decision (RED) for Naphthalene,* dated April
21, 2008.

[]{.mark}

[]{#__RefHeading___Toc213557893 .anchor}**4. Endocrine Disruption**

EPA is required under the Federal Food, Drug, and Cosmetic Act (FFDCA),
to develop a screening program to determine whether certain substances
(including all pesticide active and other ingredients) "may have an
effect in humans that is similar to an effect produced by a naturally
occurring estrogen, or other such endocrine effects as the Administrator
may designate." Following recommendations of its Endocrine Disruptor
Screening and Testing Advisory Committee (EDSTAC), EPA determined that
there was a scientific basis for including, as part of the program, the
androgen and thyroid hormone systems, in addition to the estrogen
hormone system. EPA also adopted EDSTAC's recommendation that the
Program include evaluations of potential effects in wildlife. For
pesticide chemicals, EPA will use FIFRA and, to the extent that effects
in wildlife may help determine whether a substance may have an effect in
humans, FFDCA authority to require the wildlife evaluations. As the
science develops and resources allow, screening of additional hormone
systems may be added to the Endocrine Disruptor Screening Program
(EDSP).

When additional appropriate screening and/or testing protocols being
considered under the Agency's EDSP have been developed, naphthalene may
be subjected to further screening and/or testing to better characterize
effects related to endocrine disruption.

5.  []{#__RefHeading___Toc213557894 .anchor}**Dietary Risk (Water
    Only)**

There are no agricultural or food-related pesticide uses of naphthalene;
therefore, no dietary exposure from food is expected. There is potential
for drinking water exposure, since naphthalene is registered for
residential outdoor use an animal repellant.

a.  **Estimated Drinking Water Exposure**

Number range CHAPTER A Tier I aquatic exposure assessment was conducted
using FIRST (FQPA Index Reservoir Screening Tool), which is a program
that calculates acute, as well as longer-term, estimated environmental
concentration (EEC) values in surface water. FIRST considers reduction
in dissolved pesticide concentration due to adsorption of a pesticide to
soil or sediment, incorporation, degradation in soil before washoff to a
water body, direct deposition of spray drift into the water body, and
degradation of the pesticide within the water body.

Given the limited use of this compound in an outdoor setting and the
fact that it is applied in a band around ornamentals, planting beds, and
building perimeters as a repellent, an adjustment to the modeled EEC was
made assuming 4.1% of a typical residential lot would be treated. The
resultant FIRST EEC has been adjusted by this factor.

Two scenarios were modeled to represent both high and low use scenarios.
The high use scenario was modeled at 10.8 lbs active ingredient/acre
(ai/A) with six applications per year, while the low use scenario was
modeled at 0.56 lbs ai/A with six applications per year. The modeling
results are summarized in Table 3.

+----------------+----------------+-----------------+--------+-------+
| **Table 3.     |                |                 |        |       |
| Results of     |                |                 |        |       |
| FIRST Modeling |                |                 |        |       |
| for            |                |                 |        |       |
| Naphthalene**  |                |                 |        |       |
+================+================+=================+========+=======+
| **Use Site**   | **Application  | **Number of     | **Peak | **A   |
|                | Rate           | Applications**  | EEC    | nnual |
|                | (lbs/acre)**   |                 | (      | Av    |
|                |                | **(interval)**  | ppb)** | erage |
|                |                |                 |        | EEC   |
|                |                |                 |        | (p    |
|                |                |                 |        | pb)** |
+----------------+----------------+-----------------+--------+-------+
| Ornamentals    | 10.8           | 6               | 43.4   | 6.5   |
| for rabbit &   |                |                 |        |       |
| dog repellent  |                | (2 months)      |        |       |
+----------------+----------------+-----------------+--------+-------+
| Ornamentals    | 0.56           | 6               | 2.2    | 0.3   |
| for snake      |                |                 |        |       |
| repellent      |                | (2 months)      |        |       |
+----------------+----------------+-----------------+--------+-------+

Unaccounted for in this exposure assessment is the fact that naphthalene
is volatile. Given the potential volatility of this compound and the
fact that the Tier I model used to estimate exposure does not account
for volatility as a route of dissipation, it is likely that the exposure
estimates derived above are over-predictions of potential exposure to
naphthalene in drinking water derived from surface water sources.

The Tier I Screening Concentration in Ground Water (SCI-GROW) model was
used to estimate naphthalene residues in groundwater. Because the EECs
for groundwater residues (ranging from 4.5 to 0.2 ppb) are lower than
those for surface water, the FIRST surface water exposure estimates are
used for the drinking water risk assessment and are considered to be
protective.

**b. Reference Dose**

Number range CHAPTER

Number range CHAPTER Dietary risk assessment incorporates both exposure
to and toxicity of a given pesticide. For chemicals with no food uses,
such as naphthalene, acute and chronic dietary risk is expressed as a
percentage of the acute or chronic Reference Dose (RfD). The RfD is the
POD (NOAEL or LOAEL) divided by uncertainty factors (UFs). A total UF of
1000 was applied to both the acute and chronic LOAELs to calculate the
acute and chronic RfDs, respectively. To estimate risks from potential
dietary exposure to naphthalene, exposure estimates are compared to the
acute or chronic RfDs. An acute or chronic exposure that is less
than100% of the acute or chronic RfD is not of concern.

**c**. **Dietary (Drinking Water Only) Risk Estimates**

The dietary exposure and risk estimates resulting from intake of water
with residues of naphthalene were determined for the general U.S.
population and all population sub-groups using the Dietary Exposure
Evaluation Model (DEEM-FCID), which uses food consumption data from the
U.S. Department of Agriculture's Continuing Surveys of Food Intakes by
Individuals (CSFII) from 1994-1996 and 1998. The screening-level acute
drinking water assessment using the DEEM-FCID Model was reported at the
95^th^ percentile of exposure for the general U.S. population and all of
its sub-groups. It is based exclusively on the peak EEC of 43.4 ppb for
all direct and indirect drinking water sources. Risk estimates were all
found to be well below the 100% acute Reference Dose (aRfD) threshold
level of concern. The acute drinking water exposure for naphthalene was
estimated to be 0.0023 mg/kg/day at 0.6% of the aRfD for the general
U.S. population. The acute drinking water exposure for the most highly
exposed population subgroup, all infants, was estimated to be 0.0085
mg/kg/day at 2.1% of the aRfD.

The chronic screening-level drinking water assessment is another
conservative evaluation based exclusively on the annual average EEC of
6.5 ppb for all direct and indirect drinking water sources. Risk
estimates were all found to be well below the 100% chronic Reference
Dose (cRfD) threshold level of concern. The chronic drinking water
exposure for naphthalene was estimated to be 0.0001 mg/kg/day at 0.1% of
the cRfD for the general U.S. population. The chronic drinking water
risk for the most highly exposed population sub-group, all infants, was
estimated to be 0.0004 mg/kg/day at 0.4% of the cRfD.

As previously noted, a drinking water assessment for naphthalene was
carried out by the Agency for its use as a pest repellant outdoors
around the home. This screening-level assessment relied on modeling
analyses to calculate EECs for drinking water. Given the potential
volatility of this compound and the fact that the Tier I model used to
estimate exposure does not account for volatility as a route of
dissipation it is likely that the EECs are overestimated. Additionally,
the dietary (drinking water only) assessment used only the high end EECs
from a maximum use rate and the resulting risk estimates, while not of
concern, can be considered upper bound. Although a number of potential
water degradates have been identified, the drinking water assessment is
only for the parent compound naphthalene. There were no data on the
environmental fate of the degradates, or on the toxicity of the
degradates in relation to the parent. However, given the overall
conservative nature of the water assessment it is unlikely that risks
from exposure to naphthalene in drinking water were underestimated.

Available water monitoring data, while non-targeted, indicate that
naphthalene was infrequently detected in water supplies, and those
detects were usually well below the Health Reference Level (HRL) of 140
ppb. EPA's Office of Water has concluded that the regulation of
naphthalene in drinking water is unlikely to represent a meaningful
opportunity for health risk reduction. While it is not known if detects
in ambient water are from pesticide or industrial uses, it should be
noted that about 190,000 lbs of naphthalene a year is used for outdoor
pest control compared to the approximately 1.8 billion lbs of
naphthalene used for the US jet fuel market.

6.  []{#__RefHeading___Toc213557895 .anchor}**Residential
    (Non-Occupational) Exposure Risk**

The Agency has determined that there is a potential for exposure (dermal
and inhalation) in residential settings during the application process
for homeowners who purchase and use pesticide products containing
naphthalene. There is also a potential for postapplication inhalation
exposure from inhabiting indoor areas previously treated with
naphthalene, as well as potential (postapplication) episodic ingestion
exposure to toddlers.

To quantitatively estimate residential risks, the Agency calculates a
margin of exposure (MOE), which is the ratio of the endpoint derived
from a toxicity study (NOAEL) to the exposure. This MOE is compared to a
level of concern (LOC), which is the same value as the uncertainty
factor (UF) applied to the endpoint. For naphthalene, the uncertainty
factors are 100 for both dermal and episodic ingestion exposures. A
summary of naphthalene residential risk follows. For further information
on residential risk, refer to the *Naphthalene: Phase 4 Amendment:
Response to Comments In Reference to "Naphthalene: Occupational and
Residential Exposure Assessment and Recommendations for the
Reregistration Eligibility Decision Document,*" dated September 10,
2008.

A quantitative exposure assessment was performed for homeowners applying
naphthalene in the residential environment (dermal) and for toddler
episodic (oral) ingestion of naphthalene used for indoor/outdoor
treatments. Human health risk estimates were not calculated for
postapplication inhalation scenarios because of the uncertainties
associated with extrapolating animal (rodent) data to humans as
discussed previously in this document. Rather than quantifying
inhalation (cancer and noncancer) risks to humans, the levels of ambient
naphthalene measured in the human exposure study were compared directly
to the levels resulting in 1) no adverse effects in the rodent studies
(NOAELs) and 2) a toxic effect in rodents (LOAELs). This comparison
provides a sense of the difference between actual naphthalene
concentrations that a human may encounter and the doses which elicit
either no adverse response or a toxic response in rodents.

**a. Residential Handler Risk**

The Agency determined that there is potential for exposure in
residential settings during the application process for homeowners who
purchase and use naphthalene-containing products. According to label
instructions, homeowners must physically place naphthalene formulations
into indoor storage areas and around the perimeter of outdoor areas to
be protected. The Agency anticipates handler dermal and inhalation
exposure during the application process. However, as previously
described, the Agency did not select an inhalation endpoint, nor is
there inhalation exposure data available to assess this handler
scenario. Furthermore, data for acute (15 minute) inhalation exposure
were used in conjunction with animal studies to derive a direct
comparison for postapplication inhalation exposure to areas treated with
naphthalene. The Agency assumes that the acute postapplication
inhalation assessment is protective for handler inhalation exposure.
Measured concentrations of naphthalene would likely be greater in the
acute post-application exposure scenario due to the time allotted in the
exposure study (4-6 days) for the vapors of the product to accumulate in
the enclosed areas that would be accessed than a handler would
experience during an application event. Therefore, only dermal handler
exposure was quantitatively assessed.

Applications of naphthalene are expected to be short-term in nature
because the products are typically applied only intermittently and
usually on a seasonal basis, *i.e.* when storing winter clothes or when
outdoor pests are active. As a result, no intermediate-term or long-term
exposure scenarios were assessed for handlers.

Exposure data for the residential handler dermal assessment were taken
from the exposure study, "Estimation of Homeowner Exposure to LX1298-01
(Naphthalene) Resulting from Simulated Residential Use as an Insect
Repellent" (MRID 43716501). EPA determined that this study utilized
adult human subjects that were intentionally exposed, and therefore,
required review of its ethical conduct; the study has received that
review, and it was concluded that there are no regulatory barriers to
EPA's reliance on this study in its actions under FIFRA. In the study,
dermal handler exposure data was derived from the result of monitoring a
person weighing out and placing mothballs in a closet and dresser at
three different locations. In addition, standard assumptions for
residential applicators were used.

The residential handler dermal MOEs for both scenarios assessed
(applying mothballs and animal repellant treatments) were greater than
100 (MOE = 28,000 and 17,000, respectively) and, therefore, are below
the Agency's LOC.

b.  **Residential Postapplication Risk**

    i.  **Episodic Ingestion Risk**

Naphthalene applications are made indoors for moth treatments and
indoors/outdoors for animal repellency. The Agency anticipates that
toddlers could come in contact with naphthalene formulations inside a
treated home or in treated outdoor areas. While labels specify that
indoor moth treatments be made in airtight containers, it is assumed
that a toddler could potentially access these areas and ingest
naphthalene products. Outdoor applications of naphthalene are labeled
for use around the perimeter of areas to be protected. While a toddler
could potentially access outdoor treated areas, naphthalene incident
reports indicate that a large majority of incidents for children under
six years old are from ingestion of indoor products.

Inhalation and episodic ingestion routes of exposure were not combined
for toddlers in order to differentiate the occurrence of a discrete
accidental event (assessed to give a worst-case estimate of risk) from
the expected daily exposure via the inhalation route. It would not be
appropriate to combine episodic exposure for comparison to a short-(or
longer) term endpoint.

The Agency's standard assumptions and risk assessment procedures were
used to derive the potential dose rate of a toddler ingesting one
mothball, which was then compared to the incidental oral endpoint to
calculate an MOE. In addition, the Agency estimated the amount of a
single mothball that a toddler could ingest to result in an MOE of 100.

Toddler episodic ingestion of one naphthalene mothball results in an MOE
\< 1 and, therefore, is of concern (LOC = 100). An oral dose of 0.5
mg/kg/day would be required to result in an MOE of 100. This dose is
equivalent to a toddler ingesting less than 1% of one mothball.

It is important to note that the episodic ingestion MOE is calculated
from an endpoint derived from a developmental oral rat study in which
dams were repeatedly treated with a high oral bolus dose and the
resulting clinical signs (lethargy and slow breathing) and body weight
decrement were transient. The effects were attributed to the
administration of a high bolus and were not permanent; the animals
displayed quick recovery. There were no persistent effects or
treatment-related deaths. While the episodic ingestion of naphthalene by
a toddler results in an MOE below the LOC, and does represent an
exposure concern, the effects of this type of exposure, if any, are not
expected to be severe. The study results are consistent with what might
be inferred from the incident reports, which are described in more
detail below.

ii. **Inhalation (Cancer and Noncancer) Risk**

The Agency has determined that there is potential for inhalation
exposure to adults and children from naphthalene applications made
indoors for moth treatments and animal repellency, and to a lesser
extent, outdoors for animal repellency. While labels specify that
treated indoor areas should be airtight to be effective, the Agency
anticipates that naphthalene will volatilize and be inhaled by adults
accessing treated areas (*i.e.*, containers, dresser drawers, closets,
etc.) and by adults and children that inhabit treated areas exposed to
ambient concentrations of naphthalene. Exposures from accessing treated
areas are expected to be acute (approximately 15 minutes) in duration,
and exposures from inhabiting treated areas are short-(\<1 month),
intermediate- (1-6 months), and long-term (\>6 months) in duration.

As previously described, there is support from published studies and
ongoing research on naphthalene that indicate that risk estimates,
factoring in known species differences between rodents and primates
(including humans) in metabolism and respiratory toxicity, would be
considerably less than those using default procedures. Therefore, rather
than quantifying inhalation risks to humans, the levels of ambient
naphthalene measured in the human exposure study were compared directly
to the levels resulting in a 1) no adverse effects in the rodent studies
(NOAELs) and 2) a toxic effect in rodents (LOAELs). This comparison
provides a sense of the difference between actual naphthalene
concentrations that a human may encounter and the doses which elicit
either no adverse response or a toxic response in rodents.

Anticipated acute and short-term exposures were calculated using
standard assumptions and the results of the aforementioned naphthalene
exposure study (MRID 43716501). The 15 minute (acute) and 24 hour
(short-term) samples resulted in average concentrations of 0.85 and 0.66
mg/m^3^ of naphthalene, respectively. These values were compared
directly to the animal LOAEL (10 ppm or 52 mg/m^3^) and NOAEL (3 ppm or
16 mg/m^3^) selected for acute and short-term exposure durations.\
 \
Estimated acute and short-term exposures to naphthalene in residences
are 20X and 30X, respectively, below the rodent dose resulting in no
adverse effects (NOAEL). Anticipated acute and short-term exposures to
naphthalene in residences are 60X and 80X, respectively, below the
rodent dose resulting in respiratory toxicity, specifically olfactory
epithelium lesions (LOAEL).

 \
Anticipated intermediate- and long-term exposures were also calculated
using standard assumptions; however, because of the lack of a
naphthalene-specific study of an appropriate duration, a different
exposure study was used to assess these durations of exposure
("Polycyclic Aromatic Hydrocarbon Exposure of Children in Low-Income
Families, Chuang et al., 1999"). This study was reviewed for its ethical
conduct, and it was concluded that it does not meet the regulatory
definition of research involving intentional human exposure. Therefore,
it is not required to undergo ethical review and that there are no
regulatory, ethical, or policy barriers to using this study for risk
assessment. The study was conducted to observe exposures to polycyclic
aromatic hydrocarbons (PAHs), including naphthalene, inside of 24 homes
from air, dust, soil, and food. This study is not specific to
intermediate- or long-term exposure durations, nor does naphthalene
necessarily originate from a mothball source; however, it has been
identified as the best available data source to account for naphthalene
volatilization and dissipation over time. Due to the uncertainty
associated with the use of an exposure study which is not specific to
the duration assessed, the Agency selected the most conservative
exposure value (*i.e.*, maximum concentration observed) to represent
intermediate- and long- term exposure levels. During reregistration for
naphthalene, a Data Call-In will be issued requiring a confirmatory
chamber study to determine levels of naphthalene in the air resulting
from use of mothballs at the maximum label rate.

The indoor ambient samples which pertain to the air concentrations of
naphthalene resulted in a maximum level of 0.0097 mg/m^3^. This exposure
value was directly compared to the animal LOAEL for olfactory epithelium
lesions selected for intermediate- (2 ppm or 10 mg/m^3^ identified in a
nose-only study) and long-term (10 ppm or 52 mg/m^3^ identified in an
exposure chamber study) durations, as well as to the NOAEL selected for
the intermediate-term duration (1 ppm or 5.2 mg/m^3^). A NOAEL was not
identified for long-term inhalation exposure.

Intermediate- and long-term exposures to naphthalene in residences are
1000X and 5400X, respectively, below the animal dose (LOAEL) resulting
in respiratory toxicity (olfactory epithelium lesions) and
intermediate-term exposure is 540X below the animal dose NOAEL. The
long-term duration was not assessed since a NOAEL was not identified.

Generally, in the absence of information on kinetics/dynamics, it is
assumed that humans may be 10 times more sensitive than animals (10X
interspecies factor). The current research indicates that primates, thus
humans, are less sensitive than rodents because of differences in the
rate of bioactivation of naphthalene as well as anatomical and
physiological differences in the nose and respiratory tract. These
critical differences between primates and rodents have not been
accounted for in this assessment. Thus, with consideration of
differences in dosimetry and species metabolism of naphthalene, the
margins of exposure for human inhalation risk assessment are likely
larger than the differences calculated here between the rodent NOAELs
and LOAELs and the measured ambient naphthalene levels from the best
available exposure study.

Studies determining the differences in nasal metabolism of naphthalene
between rodents and primates are part of ongoing research. There are no
data to indicate that humans have a slower rate of clearance, but if
they did, then there would be a longer time for humans to produce the
active metabolite.  These issues are being addressed in current
pharmacokinetic research.

[]{#__RefHeading___Toc213557896 .anchor}**7. Aggregate Risk**

An aggregate risk assessment for all expected routes of exposure was not
performed as there is no common toxicity among all the routes of
exposure. A short-term aggregate risk assessment could be performed by
combining short-term incidental oral exposure and average/background
dietary (in this case drinking water) exposures. However, a short-term
aggregate risk assessment was not performed for naphthalene since the
short-term incidental oral exposure risk estimate alone exceeds the LOC,
and combining with other routes of exposure would only further exceed
the LOC.

[]{#__RefHeading___Toc213557897 .anchor}**8. Occupational Risk**

Naphthalene pesticide products are not registered for occupational use
and, therefore occupational exposure to the pesticidal uses of
naphthalene is not anticipated and has not been assessed

[]{#__RefHeading___Toc213557898 .anchor}**9. Human Incident Data**

Four databases were consulted for poisoning incident data on naphthalene
for the period of 1993 to 2005. These include: OPP Incident Data System
(IDS), Poison Control Centers (PCC), California Department of Pesticide
Regulation, and National Institute of Occupational Safety and Health's
Sentinel Event Notification System for Occupational Risks (NIOSH
SENSOR). A summary of the findings from the *"Review of Naphthalene
Incident Reports,"* dated June 25, 2007 is as follows:

-   Naphthalene produces a disproportionately high number of exposure
    incidents when compared to the composite average of exposure
    incidents reported for all other pesticides. This pattern observed
    in the combined population (occupational, non-occupational,
    children) is largely due to the frequency of reported incidents
    among children less than 6 years;

-   Exposure to children is much higher than a typical pesticide;

-   Naphthalene PCC data show average results of about 1647
    exposures/year, 133 symptomatic cases/year, and 310 cases/year seen
    in a heath care facility;

-   No apparent annual trend is evident in the 13 year-span of data
    collected, as the number of reported incidents/year has remained
    relatively stable;

-   NIOSH/SENSOR data indicate that indoor uses of naphthalene are
    responsible for a large number of cases; and

-   The large majority of incidents for children under 6 years of age
    were from ingestion of mothball products used indoors.

    Reported incidents of naphthalene ingestion among children account
    for the majority of reported exposures, and occur with much greater
    frequency than for most other pesticides. This may be attributed to
    the widespread use of naphthalene products in homes and the ease of
    accessing the product as it is applied as loose mothballs. The
    severity of the reported incidents are much lower than for other
    pesticides as a whole. From a 13-year period of PCC data,
    approximately 7% of naphthalene incidents in children resulted in
    any symptoms at all, and less than 1% had moderate or major
    symptoms. Symptoms that did occur (both adults and children; all
    routes of exposure) were not life-threatening and include nausea,
    vomiting, headache, dizziness, drowsiness/lethargy, eye irritation,
    respiratory irritation, and dermal edema and erythema.

    []{#__RefHeading___Toc213557899 .anchor}**B. Environmental Risk
    Assessment**

Indoors, naphthalene is used principally as mothballs, and this use is
not considered likely to result in exposure to non-target organisms
(other than humans), and therefore, is not considered in the ecological
risk assessment. It is also used indoors in attics as an animal
repellant (*e.g.*, Chaperone Squirrel and Bat Repellent), and while
there is potential for exposure to animals from this use, it only
affects pest species trying to enter homes. Currently, four registered
naphthalene products include outdoor uses. These products are formulated
as flakes or granules, and are applied in a band around ornamentals,
planting beds and gardens as an animal repellent. The following is a
summary of EPA's revised ecological risk assessment for naphthalene, as
presented fully in the *Revised Ecological Risk Assessment for
Reregistration Eligibility Decision (RED) for Naphthalene,* dated April
21, 2008. This document is available in the OPP Public Docket, docket
number EPA-HQ-OPP-2008-0343, and may also be accessed through the
Agency's website at
[https://www.regulations.gov](https://www.regulations.gov/).

For naphthalene, ecological risk was assessed to determine the potential
for acute effects (*i.e.,* lethality) to mammals, birds, fish and
invertebrates using screening-level risk assessment models. Risk was
assessed for the treated site for birds and mammals, and in an adjacent
pond for freshwater fish and invertebrates. Ecotoxicity data on
sublethal (*e.g.,* reproductive, growth) effects were not available, so
chronic risk was not addressed.

Number range CHAPTERTo estimate potential ecological risk, EPA
integrates the results of exposure and ecotoxicity studies using the
risk quotient method. A risk index (RQ or LD~50~/ft^2^) is calculated by
dividing acute estimated environmental concentrations (EECs) by
ecotoxicity values for various wildlife species. The LD~50~/ft^2^ (for
terrestrial animals) or RQ (for aquatic animals) is then compared to the
Agency's Levels of Concern (LOCs), which serve as criteria for
categorizing potential risk to non-target species. At the screening
level, the Agency presumes that there is not an unreasonable risk for a
particular category if the risk quotient is below the LOC. If calculated
RQs exceed the LOC, the Agency presumes that there is a potential for
risk in that category. See Table 4 below for the Agency's ecological
LOCs. Risk characterization provides further information on potential
adverse effects and the possible impact of those effects by considering
the fate of the chemical and its degradates in the environment,
organisms potentially at risk, and the nature of the effects observed.

+--------------------------------------------------+-----+-----+-----+
| **Table 4. EPA's Ecological Levels of Concern    |     |     |     |
| (LOCs) and Risk Presumptions**                   |     |     |     |
+==================================================+=====+=====+=====+
| **If a calculated RQ is greater than the LOC     | *   | *   | *   |
| presented, then the Agency presumes that...**    | *LO | *LO | *LO |
|                                                  | C** | C** | C** |
|                                                  |     |     |     |
|                                                  | *   | **a | *   |
|                                                  | *te | qua | *pl |
|                                                  | rre | tic | ant |
|                                                  | str | ani | s** |
|                                                  | ial | mal |     |
|                                                  | ani | s** |     |
|                                                  | mal |     |     |
|                                                  | s** |     |     |
+--------------------------------------------------+-----+-----+-----+
| **Acute Risk ...**there is potential for acute   | 0.5 | 0.5 | 1.0 |
| risk; regulatory action may be warranted in      |     |     |     |
| addition to restricted use classification        |     |     |     |
+--------------------------------------------------+-----+-----+-----+
| **Acute Endangered Species ...**endangered       | 0.1 | 0   | 1.0 |
| species may be adversely affected                |     | .05 |     |
+--------------------------------------------------+-----+-----+-----+
| **Chronic Risk** ...there is potential for       | 1   | 1   | NA  |
| chronic risk                                     |     |     |     |
+--------------------------------------------------+-----+-----+-----+

[]{#__RefHeading___Toc213557900 .anchor}**1. Environmental Fate and
Transport**

There are no acceptable fate studies for naphthalene. A single
supplemental study has been provided which summarizes open literature
data on adsorption/desorption and aerobic soil metabolism data (MRID
45346801). Other fate parameters needed to conduct the ecological
assessment have either been extrapolated from the open literature data
(*e.g.,* aerobic aquatic metabolism half life) or conservatively assumed
to be stable (photolysis and hydrolysis). The lack of these data
provides uncertainty to this assessment. Elimination of this uncertainty
would require submission of additional data for these fate processes.
However, the data used in the assessment are sufficient to allow
evaluation of potential risk, and no additional environmental fate data
are needed for current outdoor uses of naphthalene.

Open literature data indicated that the solubility of naphthalene ranged
from 30 to 31.7 mg/L and that the Koc ranged from 200 to 1470 for a
variety of soils from North America, Europe and China. The study
citation concluded that naphthalene was bound relatively rapidly to
soils with a sustained desorption over days to weeks. For
biodegradation, naphthalene degraded with aerobic soil metabolism
half-lives between 3.5 and 40 days with no appreciable degradation under
anaerobic conditions. Possible dissipation processes affecting
naphthalene include volatilization, bioaccumulation, adsorption, and
leaching. Volatilization is the method by which naphthalene is effective
as an animal repellant. Data suggest that once in air, naphthalene
should degrade or dissipate rapidly. Naphthalene principally dissipates
via direct sublimation from granules, but data suggests that if
naphthalene does enter soil, up to 30% of loss from soil can occur due
to volatilization.

Additional open literature data describe both aerobic soil degradation
and adsorption values that are consistent with values described above,
although under certain conditions degradation from soil may be somewhat
longer. In addition, these data suggest that naphthalene degrades
rapidly by aqueous photolysis. The data also suggest that under certain
conditions naphthalene dissipates rapidly from open water systems,
although it is unclear whether the dissipation observed was due to
degradation or lumped dissipation processes including transport out of
the systems by flowing water. Finally, these data confirm that
naphthalene is relatively stable under anaerobic conditions.

A number of transformation products were identified in the various open
literature studies. The study author proposed a degradation pathway for
naphthalene, which ultimately resulted in catechol. Transitional
transformation products included
cis-1,2-dihydroxy-1,2-dihydronapthalene, 1,2-dihydroxy-napthalene,
2-hydroxchromene-2-carboxylate (HCCA),
trans-o-hydroxy-benzylidenpyruvate (tHBPA), salicyladehyde, and
salicylate. There are no registrant submitted environmental fate data on
these degradation products that would allow for an approximation of
environmental fate inputs, the available open literature data are
sparse, and there are no available toxicity data for these compounds.
Therefore, these degradates were not quantitatively assessed in the
exposure assessment, and risk estimates are based on the parent only.

2.  []{#__RefHeading___Toc213557901 .anchor}**Terrestrial Organisms**

    **a. Exposure**

Naphthalene's outdoor products are formulated as flakes or granules, and
are applied in bands 1 to 12 inches wide around ornamental plants,
gardens, or building perimeters (snake products only). For birds and
rabbits, naphthalene products are formulated with 100% naphthalene ai.
This is roughly equivalent to an application rate of 10.8 lbs ai/A.
Snake repellant products consist of 7% naphthalene (*i.e.* 0.56 lbs
ai/A). For modeling purposes, granules are used as a surrogate for
flakes. The Tier-1 model, T-REX (Terrestrial Residue Exposure), was used
to estimate terrestrial exposure and risk values for naphthalene. Input
values on avian and mammalian toxicity, as well as chemical application
and foliar dissipation half-life data, are required to run the model. A
default dissipation half-life of 35 days was assumed. The LD~50~/ft^2^
is used to estimate risk for granular formulations through row and
banded applications. Number range CHAPTERNumber range CHAPTERThe
appropriate T-REX input parameters were selected from the product
labels. For the method of application using granules (or flakes), one
row length of 209 feet with a 1-foot bandwidth and 0% incorporation was
assumed. These parameters are summarized in Table 5 below. Since
naphthalene is used only as a granular or flake application, exposures
to animals foraging on food items with naphthalene residues (short and
tall grass, broadleaves, seeds) are not estimated in this assessment.

+----------+----------+--------+------------------+------------------+
| **Table  |          |        |                  |                  |
| 5. Input |          |        |                  |                  |
| Pa       |          |        |                  |                  |
| rameters |          |        |                  |                  |
| for      |          |        |                  |                  |
| T-REX    |          |        |                  |                  |
| An       |          |        |                  |                  |
| alysis** |          |        |                  |                  |
+==========+==========+========+==================+==================+
| **App    | **Formu  | **I    | **Guidance**     | **Comments**     |
| lication | lation** | nput** |                  |                  |
| Type**   |          |        |                  |                  |
+----------+----------+--------+------------------+------------------+
| R        | Granular | Number | Row spacing is   | Only one row was |
| ows/Band |          | of     | the amount of    | assumed. A row   |
|          |          | Row,   | space (inches)   | length of 209    |
|          |          | Length | between crop     | foot was used    |
|          |          |        | rows and is      | assuming         |
|          |          |        | obtained from    | application      |
|          |          |        | the product      | occurs on one    |
|          |          |        | label.           | side of a        |
|          |          |        |                  | one-acre field.  |
+----------+----------+--------+------------------+------------------+
|          |          | Band   | Bandwidth is the | A 12 inch        |
|          |          | width  | width of the     | bandwidth was    |
|          |          |        | applied          | obtained from    |
|          |          |        | pesticide row    | the Dr. T's      |
|          |          |        | (inches) and is  | Snake-A-Way      |
|          |          |        | obtained from    | label            |
|          |          |        | the product      | (registration \# |
|          |          |        | label.           | 58630-1), which  |
|          |          |        |                  | is the greatest  |
|          |          |        |                  | labeled          |
|          |          |        |                  | bandwidth.       |
+----------+----------+--------+------------------+------------------+
|          |          | \%     | Value depends on | Not incorporated |
|          |          | Incorp | the method of    | according to     |
|          |          | orated | application:     | labels.          |
|          |          |        |                  |                  |
|          |          |        | T-Banded --      |                  |
|          |          |        | covered with     |                  |
|          |          |        | specified amount |                  |
|          |          |        | of soil: 99%     |                  |
|          |          |        | In-furrow,       |                  |
|          |          |        | drill, or        |                  |
|          |          |        | shanked-in: 99%  |                  |
|          |          |        |                  |                  |
|          |          |        | Side-dress,      |                  |
|          |          |        | banded, mix, or  |                  |
|          |          |        | lightly          |                  |
|          |          |        | incorporate with |                  |
|          |          |        | soil: 85%        |                  |
|          |          |        |                  |                  |
|          |          |        | Broadcast, mix,  |                  |
|          |          |        | or lightly       |                  |
|          |          |        | incorporated:    |                  |
|          |          |        | 85%              |                  |
|          |          |        |                  |                  |
|          |          |        | Side-dress,      |                  |
|          |          |        | banded,          |                  |
|          |          |        | unincorporated:  |                  |
|          |          |        | 0%               |                  |
|          |          |        |                  |                  |
|          |          |        | Broadcast,       |                  |
|          |          |        | aerial           |                  |
|          |          |        | broadcast,       |                  |
|          |          |        | unincorporated:  |                  |
|          |          |        | 0%               |                  |
+----------+----------+--------+------------------+------------------+
|          |          | Weight | Estimated from   | 38 mg            |
|          |          | of     | data obtained    |                  |
|          |          | g      | from registrant  |                  |
|          |          | ranule |                  |                  |
+----------+----------+--------+------------------+------------------+

**b.** **Toxicity**

Effects characterization describes the potential effects a pesticide can
produce in an organism, and is generally based on registrant-submitted
studies or studies found in the open literature which describe acute and
chronic toxicity effects for various animals. Table 6 summarizes the
toxicity effects and reference values used to assess risks for
naphthalene to terrestrial organisms.

+--------+-------------+----------+-------+-----------+--------------+
| *      |             |          |       |           |              |
| *Table |             |          |       |           |              |
| 6.**   |             |          |       |           |              |
| **To   |             |          |       |           |              |
| xicity |             |          |       |           |              |
| of     |             |          |       |           |              |
| Napht  |             |          |       |           |              |
| halene |             |          |       |           |              |
| to     |             |          |       |           |              |
| Terre  |             |          |       |           |              |
| strial |             |          |       |           |              |
| A      |             |          |       |           |              |
| nimals |             |          |       |           |              |
| and    |             |          |       |           |              |
| Pl     |             |          |       |           |              |
| ants** |             |          |       |           |              |
+========+=============+==========+=======+===========+==============+
| **T    | **Test      | **Test   | **    | **Value** | *            |
| axon** | Organism**  | Type**   | Endpo |           | *Ecotoxicity |
|        |             |          | int** |           | Category**   |
+--------+-------------+----------+-------+-----------+--------------+
| **     | Bobwhite    | Acute    | L     | 2690      | Practically  |
| Bird** | quail       | Oral     | D~50~ | mg/kg     | nontoxic     |
|        |             |          |       | bw^1^     |              |
|        | *Colinus    |          |       |           |              |
|        | v           |          |       |           |              |
|        | irginianus* |          |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+
|        |             | Subacute | L     | \>5620    | Practically  |
|        |             | Dietary  | C~50~ | mg/kg     | nontoxic     |
|        |             |          |       | diet      |              |
+--------+-------------+----------+-------+-----------+--------------+
|        | Mallard     | Subacute | L     | No data   | Not          |
|        | duck        | Dietary  | C~50~ |           | available    |
|        |             |          |       |           |              |
|        | *Anas       |          |       |           |              |
|        | pla         |          |       |           |              |
|        | tyrhynchos* |          |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+
| **Ma   | Rat         | Acute    | L     | 2649      | Practically  |
| mmal** |             | Oral     | D~50~ | mg/kg bw  | nontoxic     |
|        | *Rattus     |          |       |           |              |
|        | norvegicus* |          |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+
| **Bene | Honey bee   | Acute    | L     | No data   | Not          |
| ficial |             | Contact  | D~50~ |           | available    |
| ins    | *Apis       |          |       |           |              |
| ects** | mellifera*  |          |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+
| **Soil | *Folsomia   | Chronic  | NOAEC | 88        | None         |
| Inv    | candida*    | Effects  |       | µmol/kg   |              |
| ertebr |             | on Soil  | LOAEC | soil      |              |
| ates** |             | Inver    |       |           |              |
|        |             | tebrates |       | 409       |              |
|        |             | (repr    |       | µmol/kg   |              |
|        |             | oduction |       | soil      |              |
|        |             | and      |       |           |              |
|        |             | s        |       |           |              |
|        |             | urvival) |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+
|        | *Enchytaeus |          | NOAEC | 220       | None         |
|        | crypticus*  |          |       | µmol/kg   |              |
|        |             |          | LOAEC | soil      |              |
|        |             |          |       |           |              |
|        |             |          |       | 2045      |              |
|        |             |          |       | µmol/kg   |              |
|        |             |          |       | soil      |              |
+--------+-------------+----------+-------+-----------+--------------+
| *      | Monocots    | Seedling | E     | No data   | Not          |
| *Terre | and dicots  | e        | C~25~ |           | available    |
| strial |             | mergence |       |           |              |
| pl     |             | and      | NOAEC |           |              |
| ants** |             | Ve       |       |           |              |
|        |             | getative | LOAEC |           |              |
|        |             | vigor    |       |           |              |
+--------+-------------+----------+-------+-----------+--------------+

1\. Body weight

**c. Risk to Terrestrial Organisms**

**i. Birds**

At a rate of 10.8 lbs ai/A, risk estimates for birds of all the weight
classes, exceed the Agency's LOC. However, naphthalene is a repellent
and it is manufactured to ensure that birds will avoid the naphthalene
products (*e.g.*, Dr.T's Rabbit, Squirrel, Bat, and Bird Repellent, reg.
\# 58630-2).

Although it may be unlikely that birds will consume naphthalene
granules, since it is not formulated as an attractant but as a repellent
to terrestrial animals and is comprised of granules with a strong odor
of coal tar, it is uncertain if the repellent nature of the compound
will be sufficient to keep birds away entirely. Therefore, further steps
were taken to characterize the potential for acute risk to avian species
by evaluating how many granules a bird would need to ingest in order to
trigger the Agency's LOC; these estimates are presented in Table 7.

  ----------------------------------------------------------------------------------
  **Table 7. Estimate of the                                              
  number of granules ingested                                             
  to reach an EEC exceeding                                               
  the adjusted LD~50~ LOC for                                             
  birds at 10.8 lbs ai/A**                                                
  --------------------------- --------------------- ----------- --------- ----------
                                                    **Bird Size           
                                                    (grams)**             

                                                    **20**      **100**   **1000**

  No. of Consumed Granules    Adjusted LD~50~       1           7         92
  Required                                                                

                              Acute Risk LOC (0.5)  0.51        4         46

                              Endangered Species    0.1         0.65      10
                              LOC (0.1)                                   

  EEC = 112.46 mg/square feet                                             
  (excluding row spacing,                                                 
  bandwidth, and \# of rows                                               
  input parameters).                                                      
  ----------------------------------------------------------------------------------

While the Agency believes it is unlikely that birds will consume
naphthalene, it is possible that a bird might accidentally ingest it,
and if that occurs, the screening-level assessment indicates that a
small bird (20 g) will exceed the Agency's LOC at 1 granule if eating
avian/mammalian repellant product. These risk estimates assume that
birds eat granules containing 100% ai immediately following application,
before loss of naphthalene to sublimation. One of the outdoor
formulations of naphthalene, "Dr. T's Snake-A-Way", consists of granules
that contain 7% naphthalene ai; therefore, a bird would have to consume
over 14 times more of the snake repellant granules to exceed an LOC.

Because no toxicity data are available on avian reproductive risk, the
Agency was unable to assess chronic risk to birds.

**ii. Terrestrial-phase Amphibians and Reptiles**

The Agency currently uses data on surrogate species, birds, to assess
risk to non-target terrestrial-phase amphibians and reptiles. Based on
the evaluation of potential risks to birds, potential risks to reptiles
and terrestrial-phase amphibians are also higher than the Agency's
levels of concern. However, naphthalene is a repellent and it is
formulated to repel reptiles (*e.g*., Dr. T's Snake-A-Way).

**iii. Mammals**

The acute risk estimates (LD~50~/ft^2^) to terrestrial mammals, as a
result of the assessed uses of naphthalene at 10.8 and 0.56 lbs ai/acre
exceed the LOCs for acute risk and endangered species. As for birds, the
risk estimates are based on a granular formulation.

  ---------------------------------------------------------------------------
  **Table 8.                                
  Mammalian                                 
  LD~50~/ft^2^ (RQs)                        
  from Direct                               
  Ingestion of                              
  Naphthalene                               
  Granules**                                
  ------------------- --------------------- ---------------------------------
  **Weight Class**    **LD~50~/ft^2\ A^**   **LOCs Exceeded**

  **10.8 lb ai/A -                          
  EEC/Toxicity                              
  (adjusted mg/ft^2^                        
  / adjusted                                
  LD~50~)**                                 

  15 g                268.18                Acute Risk, Endangered Species

  35 g                142.05                Acute Risk, Endangered Species

  1000 g              11.49                 Acute Risk, Endangered Species

  **0.56 lb ai/A -                          
  EEC/Toxicity                              
  (adjusted mg/ft^2^                        
  / adjusted                                
  LD~50~)**                                 

  15 g                13.91                 Acute Risk, Endangered Species

  35 g                7.37                  Acute Risk, Endangered Species

  15 g                13.91                 Acute Risk, Endangered Species

  ^A^ Mammal LD~50~ =                       
  2649 mg/kg                                
  ---------------------------------------------------------------------------

Curently, T-REX does not have the capacity to estimate the minimum
foraging area needed to allow for direct ingestion of sufficient mass of
naphthalene to achieve a dose that exceeds the LOC for mammals. However,
naphthalene is a repellent and it is manufactured to ensure that mammals
will avoid the naphthalene flakes (*e.g*., Chaperone Squirrel and Bat
Repellent, reg. \# 2724-685).

Because no toxicity data is available on mammalian reproductive risk,
the Agency was unable to assess chronic risk to mammals.

**iv. Non-Target Insects**

EPA does not estimate RQs for terrestrial non-target insects.
Furthermore, the Agency has no insect toxicity data for naphthalene.

**v. Terrestrial Plants**

The Agency currently uses terrestrial plant data to estimate potential
risks to non-target terrestrial plants from surface water runoff. Some
naphthalene labels state that the products should not be applied
directly to foliage or stems. This statement indicates that there is a
possibility of phytotoxicity. In addition, open literature suggests that
naphthalene is selectively phytotoxic to plants. However, terrestrial
plant studies have not been submitted for naphthalene, nor has data been
located in published literature. Therefore, the potential risks to
terrestrial plants are unknown.

[]{#__RefHeading___Toc213557902 .anchor}**3. Aquatic Organisms**

a.  **Exposure**

Risk to aquatic animals was assessed using Generic Estimated
Environmental Concentration (GENEEC2), a Tier 1 model that estimates
concentrations in a 1-hectare, 2-meter-deep water body adjacent to a
10-hectare treated site that drains into the water body. Since there are
no liquid outdoor use formulations of naphthalene and granular
applications are assumed, this water body is also assumed to receive no
drift from the treated site. The model assumes an area is 100% treated.
Given the limited size of the outdoor area treated (it is applied in a
band around ornamentals, planting beds and gardens) an adjustment of
4.1% to the modeled EEC was made to account for the use pattern.

Two scenarios were modeled to represent high and low naphthalene use
scenarios. The high use scenario was modeled at 10.8 lbs ai/A with six
applications per year, while the low use scenario was modeled at 0.56
lbs ai/A with six applications per year. The EECs are summarized in
Table 9.

+--------------+--------+-------------+-----+-----+-----+-----+-----+
| **Table 9.   |        |             |     |     |     |     |     |
| Results of   |        |             |     |     |     |     |     |
| GENEEC2      |        |             |     |     |     |     |     |
| Modeling for |        |             |     |     |     |     |     |
| Naphthalene  |        |             |     |     |     |     |     |
| Use on       |        |             |     |     |     |     |     |
| O            |        |             |     |     |     |     |     |
| rnamentals** |        |             |     |     |     |     |     |
+==============+========+=============+=====+=====+=====+=====+=====+
| **Use Site** | *      | **Number of | **P | **4 | *   | **  | **  |
|              | *Appli | App         | eak | day | *21 | 60- | 90- |
|              | cation | lications** | EEC | EEC | day | day | day |
|              | Rate   |             | (   | (   | EEC | EEC | EEC |
|              | (lbs/a | **(         | ppb | ppb | (   | (   | (   |
|              | cre)** | interval)** | )** | )** | ppb | ppb | ppb |
|              |        |             |     |     | )** | )** | )** |
+--------------+--------+-------------+-----+-----+-----+-----+-----+
| Ornamentals  | 10.8   | 6           | 2   | 2   | 2   | 2   | 2   |
| for rabbit & |        |             | 6.9 | 6.6 | 5.2 | 2.4 | 0.5 |
| dog          |        | (2 months)  |     |     |     |     |     |
| repellent    |        |             |     |     |     |     |     |
+--------------+--------+-------------+-----+-----+-----+-----+-----+
| Ornamentals  | 0.56   | 6           | 1.4 | 1.4 | 1.3 | 1.2 | 1.1 |
| for snake    |        |             |     |     |     |     |     |
| repellent    |        | (2 months)  |     |     |     |     |     |
+--------------+--------+-------------+-----+-----+-----+-----+-----+

Unaccounted for in this exposure assessment is the fact that naphthalene
is volatile. No product chemistry data are available, but an estimate of
the vapor pressure was made using EpiSuite
(http://www.epa.gov/opptintr/exposure/pubs/episuite.html). EpiSuite
reported an experimentally derived value for vapor pressure of 8.5
x10^-2^ mm Hg (which is consistent with the registrant reported value of
10.5 Pa, or 7.8 x 10^-2^ mm Hg), suggesting that naphthalene is
volatile. Given the volatility of this compound and the fact that the
Tier I model used to estimate exposure does not account for volatility
as a route of dissipation, it is likely that the exposure estimates
derived above are over-predictions of potential exposure. However, it is
unknown from the open literature data used in this assessment whether
the systems were closed or flow-through. If the aerobic metabolism data
(and hence the half-life used in this assessment) were flow-through,
then the degradation reported would include volatilization as a process.

It is possible that naphthalene may leach to groundwater. An overview of
US Geological Survey (USGS) National Water-Quality Assessment Program
(NAWQA) groundwater data indicates that of 6,977 samples only 37
detections of naphthalene were found. While the maximum concentration
detected was 70 ppb, there are a number of possible sources of
naphthalene contamination of groundwater, including many with
significantly higher usage (*e.g*., petroleum, jet fuel). Thus it
appears that leaching is not likely a significant route of exposure for
the pesticidal use of naphthalene. Potential groundwater leaching was
assessed using SciGrow, and a concentration of 16.3 ppb at the highest
application rate (10.8 lbs ai/A x 6 applications) and 0.84 ppb at the
lowest rate (0.56 lbs ai/A x 6 applications) was estimated. These values
are below the surface water concentrations predicted by GENEEC2, are
lower than the NAWQA values described above, and assume a much broader
area of application than anticipated for this use pattern (bands
surrounding gardens and planting beds). Given the lines of evidence
described, it is expected that as an exposure route for ecological risk
assessment, naphthalene in groundwater resulting from pesticidal use is
minimal.

Unlike the drinking water assessment described in the human health risk
assessment section of this document, the exposure values used in the
ecological risk assessment do not include the Index Reservoir (IR).
These factors represent a drinking water reservoir, not the variety of
aquatic habitats relevant to a risk assessment for aquatic animals, such
as ponds adjacent to treated fields. Therefore, the EEC values used to
assess exposure and risk to aquatic animals are not the same as those
used to assess exposure and risk to humans from pesticides in drinking
water.

**b. Toxicity**

Available freshwater and estuarine/marine fish and invertebrate acute
toxicity data suggest that naphthalene is moderately toxic to most
aquatic test species (Table 10). Chronic freshwater fish reproduction
data indicates that survival and growth are affected. Aquatic plant
growth studies with green algae were less sensitive than animals, and
naphthalene is categorized as slightly toxic to green alga. No toxicity
study with aquatic vascular plants is available for this ecological risk
assessment.

+--------+--------------------+-------------+---------+---------------+
| *      |                    |             |         |               |
| *Table |                    |             |         |               |
| 10.    |                    |             |         |               |
| To     |                    |             |         |               |
| xicity |                    |             |         |               |
| of     |                    |             |         |               |
| Napht  |                    |             |         |               |
| halene |                    |             |         |               |
| to     |                    |             |         |               |
| A      |                    |             |         |               |
| quatic |                    |             |         |               |
| Org    |                    |             |         |               |
| anisms |                    |             |         |               |
| and    |                    |             |         |               |
| Pl     |                    |             |         |               |
| ants** |                    |             |         |               |
+========+====================+=============+=========+===============+
| **T    | **Test Organism**  | *           | **Val   | **Ecotoxicity |
| axon** |                    | *Endpoint** | ue^1^** | Category**    |
|        |                    |             |         |               |
|        |                    |             | **(mg   |               |
|        |                    |             | a.      |               |
|        |                    |             | i./L)** |               |
+--------+--------------------+-------------+---------+---------------+
| Fres   | Rainbow trout      | 96-hr       | **2.0** | Moderately    |
| hwater |                    | LC~50~      |         | Toxic         |
| Fish   | *Onchorhynchus     |             | 0.86    |               |
|        | mykiss*            | NOAEC       |         |               |
|        |                    | (mortality) | 0.86    |               |
|        |                    |             |         |               |
|        |                    | NOAEC       |         |               |
|        |                    | (sublethal) |         |               |
+--------+--------------------+-------------+---------+---------------+
|        | Bluegill sunfish   | 96-hr       | 3.2     | Moderately    |
|        |                    | LC~50~      |         | Toxic         |
|        | *Lepomis           |             | 1.4     |               |
|        | macrochirus*       | NOAEC       |         |               |
|        |                    | (mortality) | 1.4     |               |
|        |                    |             |         |               |
|        |                    | NOAEC       |         |               |
|        |                    | (sublethal) |         |               |
+--------+--------------------+-------------+---------+---------------+
|        | Coho salmon        | 40D NOAEC   | *       | None          |
|        |                    |             | *0.37** |               |
|        | *Oncorhynchus      | 40D LOAEC   |         |               |
|        | kisutch*           |             | 0.67    |               |
+--------+--------------------+-------------+---------+---------------+
| Fres   | Water flea         | 48-hr       | **1.6** | Moderately    |
| hwater |                    | EC~50~      |         | Toxic         |
| Invert | *Daphnia magna*    |             | 0.48    |               |
| ebrate |                    | NOAEC       |         |               |
|        |                    | (mortality) | \>8.8   |               |
|        |                    |             |         |               |
|        |                    | NOAEC       |         |               |
|        |                    | (sublethal) |         |               |
+--------+--------------------+-------------+---------+---------------+
| Estu   | Fathead minnow     | 96-hr       | **6.6** | Moderately    |
| arine/ |                    | LC~50~      |         | Toxic         |
|        | *Pimephales        |             | NR      |               |
| Marine | promelas*          | NOAEC       |         |               |
|        |                    | (mortality) | NR      |               |
| Fish   |                    |             |         |               |
|        |                    | NOAEC       |         |               |
|        |                    | (sublethal) |         |               |
+--------+--------------------+-------------+---------+---------------+
|        |                    | Chronic     | *       | None          |
|        |                    | NOAEC       | *0.62** |               |
|        |                    |             |         |               |
|        |                    | Chronic     | NR      |               |
|        |                    | LOAEC       |         |               |
+--------+--------------------+-------------+---------+---------------+
| Est    | Pacific oyster     | 96-hr       | **199** | Practically   |
| uarine |                    | EC~50~      |         | Nontoxic      |
| /      | *Crassostrea       |             | NR      |               |
|        | gigas*             | NOAEC       |         |               |
| Marine |                    | (mortality) | NR      |               |
|        |                    |             |         |               |
| I      |                    | NOAEC       |         |               |
| nverte |                    | (sublethal) |         |               |
| brates |                    |             |         |               |
+--------+--------------------+-------------+---------+---------------+
|        | Grass shrimp       | 96-hr       | *       | Moderately    |
|        |                    | LC~50~      | *2.35** | Toxic         |
|        | *Palaemonetes      |             |         |               |
|        | pugio*             | NOAEC       | NR      |               |
|        |                    | (mortality) |         |               |
|        |                    |             | NR      |               |
|        |                    | NOAEC       |         |               |
|        |                    | (sublethal) |         |               |
+--------+--------------------+-------------+---------+---------------+
| Va     | Duckweed           | 7-day EC50  | No data | No Data       |
| scular |                    |             |         |               |
| Plant  | *Lemna gibba*      | NOAEC       |         |               |
+--------+--------------------+-------------+---------+---------------+
| Non-va | Green algae        | 48-hr       | **33**  | Slightly      |
| scular |                    | EC~50~      |         | Toxic         |
| Plant  | *Chlorella         |             | NR      |               |
|        | vulgaris*          | NOAEC LOAEC |         |               |
|        |                    |             | NR      |               |
+--------+--------------------+-------------+---------+---------------+

^1^Bolded values indicate toxicity thresholds used to calculate risk
quotients.

**c. Risk to Aquatic Organisms**

RQs for naphthalene do not exceed the acute LOC for aquatic animals and
aquatic nonvascular plants (*i.e.*, fish, aquatic-phase amphibians,
invertebrates, and algaes) when used at six applications, 60 days apart,
at the highest application rate (10.8 lbs ai/A). Therefore, minimal
acute risk is also expected from the lower application rate (0.56 lbs
ai/A). Risks to aquatic vascular plants are also unknown due to lack of
ecotoxicity data. Aquatic organism risk estimates based on the maximum
application rate are presented in Table 11 below.

+-----------+-----------+--------------------+--------+-----+---------+
| **Table   |           |                    |        |     |         |
| 11.**     |           |                    |        |     |         |
| **Risks   |           |                    |        |     |         |
| to        |           |                    |        |     |         |
| Aquatic   |           |                    |        |     |         |
| Animals   |           |                    |        |     |         |
| and       |           |                    |        |     |         |
| Plants    |           |                    |        |     |         |
| for       |           |                    |        |     |         |
| Na        |           |                    |        |     |         |
| phthalene |           |                    |        |     |         |
| Use on    |           |                    |        |     |         |
| Orna      |           |                    |        |     |         |
| mentals** |           |                    |        |     |         |
+===========+===========+====================+========+=====+=========+
| **Taxon** | **        | **Toxicity         | **EEC  | **R | **LOCs  |
|           | Species** | Endpoint**         | (****µ | Q^1 | Exceed  |
|           |           |                    | g/L)** | ^** | ed^2^** |
+-----------+-----------+--------------------+--------+-----+---------+
| F         | Rainbow   | 96-hr LC~50~ = 2.0 | 26.9   | 0.  | None    |
| reshwater | trout     | mg/L               | (peak) | 013 |         |
| Fish      |           |                    |        |     |         |
|           | *Onch     | (or 2000 µg/L)     |        |     |         |
|           | orhynchus |                    |        |     |         |
|           | mykiss*   |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
|           | Coho      | 40-day NOAEC =     | 22.4   | 0   | None    |
|           | salmon    | 0.37 mg/L          | (60D)  | .06 |         |
|           |           |                    |        |     |         |
|           | *Onc      | (or 370 µg/L)      |        |     |         |
|           | orhynchus |                    |        |     |         |
|           | kisutch*  |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
| F         | Water     | 48-hr LC~50~ = 1.6 | 26.9   | 0.  | None    |
| reshwater | flea      | mg/L               | (peak) | 017 |         |
| Inv       | *Daphnia  |                    |        |     |         |
| ertebrate | magna*    | (or 1600 µg/L)     |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
| Marine/   | Fathead   | LC~50~ = 6.6 mg/L  | 26.9   | \<0 | None    |
| estuarine | minnow    |                    | (peak) | .01 |         |
| Fish      |           | (or 6600 µg/L)     |        |     |         |
|           | *P        |                    |        |     |         |
|           | imephales |                    |        |     |         |
|           | promelas* |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
|           |           | NOAEC = 0.62 mg/L  | 22.4   | 0   | None    |
|           |           |                    | (60D)  | .04 |         |
|           |           | (or 620 µg/L)      |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
| Marine/   | Grass     | LC~50~ = 2.35 mg/L | 26.9   | 0   | None    |
| estuarine | shrimp    |                    | (peak) | .01 |         |
| Inv       |           | (or 2350 µg/L)     |        |     |         |
| ertebrate | *Pal      |                    |        |     |         |
|           | aemonetes |                    |        |     |         |
|           | pugio*    |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
| Vascular  | Duckweed  | No data            | 26.9   | Not |         |
| Plant     |           |                    | (peak) | ava |         |
|           | *Lemna    |                    |        | ila |         |
|           | gibba*    |                    |        | ble |         |
+-----------+-----------+--------------------+--------+-----+---------+
| F         | Green     | EC~50~ = 33 mg/L   | 26.9   | \<0 | None    |
| reshwater | Algae     |                    | (peak) | .01 |         |
| Non       | *         | (or 33000 µg/L)    |        |     |         |
| -Vascular | Chlorella |                    |        |     |         |
| Plant     | vulgaris* |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+
| ^1^ Acute |           |                    |        |     |         |
| risk      |           |                    |        |     |         |
| q         |           |                    |        |     |         |
| uotients= |           |                    |        |     |         |
| EE        |           |                    |        |     |         |
| C/LC~50~; |           |                    |        |     |         |
| Chronic   |           |                    |        |     |         |
| Risk      |           |                    |        |     |         |
| Quotients |           |                    |        |     |         |
| =E        |           |                    |        |     |         |
| EC/NOAEC. |           |                    |        |     |         |
|           |           |                    |        |     |         |
| ^2^       |           |                    |        |     |         |
| Aquatic   |           |                    |        |     |         |
| animal    |           |                    |        |     |         |
| acute     |           |                    |        |     |         |
| LOC:      |           |                    |        |     |         |
| \>0.05    |           |                    |        |     |         |
| for       |           |                    |        |     |         |
| e         |           |                    |        |     |         |
| ndangered |           |                    |        |     |         |
| species   |           |                    |        |     |         |
| and \>0.5 |           |                    |        |     |         |
| for       |           |                    |        |     |         |
| n         |           |                    |        |     |         |
| on-listed |           |                    |        |     |         |
| species;  |           |                    |        |     |         |
| LOC for   |           |                    |        |     |         |
| aquatic   |           |                    |        |     |         |
| plants:   |           |                    |        |     |         |
| \>1;      |           |                    |        |     |         |
| Chronic   |           |                    |        |     |         |
| LOC for   |           |                    |        |     |         |
| aquatic   |           |                    |        |     |         |
| animals:  |           |                    |        |     |         |
| \>1.      |           |                    |        |     |         |
+-----------+-----------+--------------------+--------+-----+---------+

**d. Endangered Species**

The acute risk to birds, terrestrial-phase amphibians and reptiles, and
mammals exceed the endangered species LOC, and therefore there is a
potential for direct effect to these taxa. In addition, there is a
potential for indirect effects to species that depend on them. The data
are currently insufficient to determine if there is a potential for
direct or indirect effect to terrestrial or aquatic plants. Naphthalene
is not likely to affect aquatic animals (fish or invertebrates)
directly; the potential for indirect effects depends on whether
naphthalene could affect semi-aquatic or aquatic plants.

**e. Ecological Incidents**

Number range CHAPTER A search of the EIIS (Environmental Incident
Information System) database for ecological incidents (run on May 31,
2007) identified one ecological incident involving naphthalene. The
incident reported includes possible impact to fish. See table 12 for
further detail.

The number of documented kills in EIIS is believed to be a very small
fraction of total mortality caused by pesticides for a variety of
reasons. An absence of reports does not necessarily equate to an absence
of incidents given the nature of incident reporting.

+--------+------+---------+----------+-------+-------+---------------+
| *      |      |         |          |       |       |               |
| *Table |      |         |          |       |       |               |
| 12.    |      |         |          |       |       |               |
| Napht  |      |         |          |       |       |               |
| halene |      |         |          |       |       |               |
| Ecol   |      |         |          |       |       |               |
| ogical |      |         |          |       |       |               |
| Inci   |      |         |          |       |       |               |
| dent** |      |         |          |       |       |               |
+========+======+=========+==========+=======+=======+===============+
| **F    | **Cr | **Date  | *        | **N   | *     | **App. Rate,  |
| ormula | op** | and     | *Species | umber | *Resi | Method,       |
| tion** |      | Loc     | Af       | Fo    | due** | etc.**        |
|        |      | ation** | fected** | und** |       |               |
|        |      |         |          |       | **    |               |
|        |      |         |          |       | Analy |               |
|        |      |         |          |       | sis** |               |
+--------+------+---------+----------+-------+-------+---------------+
| U      | N/A  | May     | Unknown  | 2,000 | No    | Treated       |
| nknown |      | 2003,   | fish     |       |       | directly      |
|        |      | Craven  |          |       |       |               |
|        |      | Co., NC |          |       |       |               |
+--------+------+---------+----------+-------+-------+---------------+

[]{#__RefHeading___Toc213557903 .anchor}**IV. Risk Management,
Reregistration, and Tolerance Reassessment Decision**

[]{#__RefHeading___Toc213557904 .anchor}**A. Determination of
Reregistration Eligibility**

Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after
submission of relevant data concerning an active ingredient, whether or
not products containing the active ingredient are eligible for
reregistration. The Agency has previously identified and required the
submission of the generic (*i.e.*, active ingredient-specific) data
required to support reregistration of products containing naphthalene as
the active ingredient. The Agency has completed its review of these
generic data, and has determined that the data are sufficient to support
reregistration of all products containing naphthalene.

The Agency has completed its assessment of the human health and
ecological risks associated with the use of pesticide products
containing naphthalene. The Agency has determined that
naphthalene-containing products are eligible for reregistration provided
that label amendments are made as outlined in Chapter V. Appendix A
summarizes the uses of naphthalene that are eligible for reregistration.
Appendix B identifies the generic data the Agency reviewed as part of
its determination of reregistration eligibility of naphthalene, and
lists the submitted studies that the Agency found acceptable.

Based on its evaluation of naphthalene, the Agency has determined that
products containing naphthalene, unless labeled and used as specified in
this document, would present risks inconsistent with FIFRA. Accordingly,
should a registrant fail to implement any of the risk mitigation
measures identified in this document, the Agency will take regulatory
action to address the risk concerns from the use of naphthalene. If all
changes outlined in this document are incorporated into the product
labels, then all current risks for naphthalene will be adequately
mitigated for the purposes of this determination under FIFRA.

[]{#__RefHeading___Toc213557905 .anchor}**B. Public Comment Period**

Through the Agency's public participation process, EPA worked with
stakeholders and the public to reach the regulatory decision for
naphthalene. EPA released the naphthalene preliminary risk assessments
for public comment on May 14, 2008, for a 60-day public comment period
(Phase 3 of the public participation process). During the public comment
period on the risk assessments, which closed on July 14, 2008, the
Agency received comments from registrants (technical and end use),
Honeywell, and the Naphthalene Council. These comments in their
entirety, responses to the comments, as well as the preliminary and
revised risk assessments, are available in the public docket
(EPA-HQ-OPP-2008-0343) at http:www.regulations.gov. In brief, the
comments included the following:

-   Landis International, the agent for the technical registrant
    (Reochem, Inc.), agrees to conduct the required exposure study
    (Guideline 875.2500).

-   An end use registrant, Willert Home Products, suggested that 1)
    packaging is not necessary to reduce potential risk from episodic
    ingestion of mothballs, since the symptoms described in incident
    reports are not severe in nature; and 2) the aquatic exposure
    modeling overestimates the amount of naphthalene product typically
    applied.

-   Honeywell International Inc. stated that the carbon adsorption
    coefficient used in the ecological risk assessment was unreasonably
    low and thus led to an unrealistically high estimate of the risks
    naphthalene poses to drinking water.

    []{#__RefHeading___Toc213557906 .anchor}**C. Regulatory Position**

    []{#__RefHeading___Toc213557907 .anchor}**1. Regulatory Rationale**

    The Agency has determined that products containing naphthalene are
    eligible for reregistration provided that specified label amendments
    are made. The following is a summary of the rationale for managing
    risks associated with the use of naphthalene. Where labelling
    revisions are warranted, specific language is set forth in the
    summary table of Section V.

a.  **Dietary Risk**

There are no agricultural or food uses of naphthalene; therefore, no
dietary exposure from food is expected. However, there is potential for
drinking water exposure from the outdoor uses of naphthalene. The acute
and chronic risk estimates were found to be well below the 100%
Reference Dose (RfD) level of concern. Overall dietary exposure to
naphthalene via drinking water is expected to be insignificant, and
thus, no mitigation measures are required.

b.  **Residential Risk**

[Handlers]{.underline}

For residential risk, the MOEs for all handler scenarios assessed were
17,000 or greater, which is greater than the Agency's MOE of 100, and
therefore, no mitigation measures are required.

[Episodic Ingestion]{.underline}

Toddler episodic ingestion of one naphthalene mothball results in an MOE
\< 1 (LOC = 100). While this represents an exposure concern, the effects
of this type of exposure, if any, are not expected to be severe. The
episodic ingestion MOE is calculated from an endpoint derived from a
developmental oral rat study in which dams were repeatedly treated with
a high oral bolus dose, and the resulting clinical signs (lethargy and
slow breathing) and body weight decrement were transient. The effects
were attributed to the administration of a high bolus and were not
permanent; the animals displayed quick recovery. There were no
persistent effects or treatment-related deaths.

The study results are consistent with symptoms described in the incident
reports. Reported incidents of naphthalene ingestion among children
account for the majority of reported naphthalene exposures. This may be
attributed to the widespread use of naphthalene products in homes and
the ease of accessing the product as it is applied as loose mothballs.
The severity of the reported incidents are much lower than for other
pesticides as a whole. From a 13-year period of PCC data (1993-2005),
approximately 7% of naphthalene incidents in children resulted in any
symptoms at all and less than 1% had moderate or major symptoms.
Symptoms that did occur (both adults and children; all routes of
exposure) were not life-threatening and included nausea, vomiting,
headache, dizziness, drowsiness/lethargy, eye irritation, and dermal
edema and erythema. Of greater concern than the potential health effects
is the accessibility of the indoor use product to young children, as
evidenced by the large number of reported incidents.

Limiting accessibility to naphthalene is expected to significantly
reduce the number of incidents, including those that may result in
symptoms. To that end, the Agency has conducted risk mitigation
discussions with the naphthalene end-use registrants. Since the large
majority of naphthalene incidents for children under 6 years of age were
from episodic ingestion of indoor use mothball products, the Agency
determined that mothballs can no longer be marketed in such a way that
individual mothballs are applied to areas accessible to children.

> The registrants have agreed to take product stewardship steps to
> ensure that products are packaged in a way that would discourage
> children from eating the product. Loose mothballs will no longer be
> sold, and there are several formulation and packaging options that
> registrants can employ instead. Mothballs can be sold in sachets, for
> example, if made with a tear- and moisture-resistant wrapping
> material. Mothballs can also be packaged in plastic containers that
> allow for volatilization, but which would prohibit direct contact with
> the naphthalene product enclosed. Alternatively, naphthalene could be
> formulated into larger sized cake or block products (minimum of 2.5
> inches in diameter), which incident data show are not an exposure
> source of concern for episodic ingestion. The registrants further
> agreed that cake and block products will also be enclosed in plastic,
> metal or cardboard packaging while in use. The implementation of
> packaging mitigation measures is required within 5 years (September
> 2013). See Table 13 for details on packaging requirements.
>
> In addition, the Agency will require prominently displayed
> precautionary label language on packaging which warns consumers of a
> possible episodic ingestion risk to children and to keep product out
> of reach of children (see Table 13). These new product labelling
> requirements will be implemented within 12 months (September 2009).
> The Agency is confident that based on the rigorous nature of the
> mitigation measures to be implemented, episodic ingestion exposures
> will be reduced to such an extent that this scenario no longer poses a
> risk of concern.

[Postapplication Inhalation (Cancer and Noncancer)]{.underline}

A quantification of cancer risk for exposures via inhalation, or
derivation of an inhalation reference concentration (RfC) for the
nonfood-pesticidal uses of naphthalene was not performed. This is
because, as described in Section III of this document, there is support
from published studies and ongoing research on naphthalene that indicate
that risk estimates, factoring in known species differences between
rodents and humans (including humans) in metabolism and respiratory
toxicity, would be considerably less than those using default
procedures. Pharmacokinetic research may quantify the species difference
and is forthcoming (approximately 2-3 years).

Anticipated acute and short-term inhalation exposures to naphthalene in
residences are estimated to be 20X and 30X below the rodent dose (NOAEL)
resulting in no adverse effects, respectively. Anticipated acute and
short-term inhalation exposures to naphthalene in residences are
estimated to be 60X and 80X, respectively, below the rodent dose (LOAEL)
resulting in respiratory toxicity (olfactory epithelium lesions).

Anticipated intermediate-term inhalation exposures to naphthalene in
residences are estimated to be 540X below the rodent dose (NOAEL)
resulting in no adverse health effects. Intermediate- and long-term
inhalation exposures to naphthalene in residences are estimated to be
1000X and 5400X, respectively, below the rodent dose (LOAEL) resulting
in respiratory toxicity (olfactory epithelium lesions).

These inhalation exposure estimates do not represent a risk of concern
to the Agency. The carcinogenic and noncarcinogenic potential of
naphthalene is currently undergoing review by EPA Integrated Risk
Information System (IRIS). The EPA process of regulating pesticides
allows for re-evaluation at any time if relevant new information becomes
available. Thus, when the IRIS assessment is finalized OPP would
determine whether the human health hazard potential of naphthalene
warrants revisiting. Similarly, when pharmacokinetic research is
complete the Agency will revisit naphthalene inhalation risk.

**c. Aggregate Risk**

An aggregate risk assessment for all expected routes of exposure was not
performed as there is no common toxicity among all the routes of
exposure. A short-term aggregate risk assessment could be performed by
combining short-term incidental oral exposure and average/background
dietary (in this case drinking water) exposures, but this was not done
for naphthalene since the short-term incidental oral exposure risk
estimate alone exceeds the LOC, and combining with other routes of
exposure would only further exceed the LOC. As previously described,
while the episodic ingestion of naphthalene by a toddler results in an
MOE less then the target MOE, the effects of this type of exposure, if
any, are transient and are not expected to be severe.

However, the Agency is requiring extensive mitigation measures,
including special packaging of indoor use products and prominent
precautionary label language. These mitigation measures are expected to
reduce the potential for episodic ingestion to such an extent that this
scenario no longer represents a risk of concern. Furthermore,
naphthalene's highly conservative dietary risk estimates for potential
drinking water exposure are far below the Agency's LOC and are not of
concern.

**d. Occupational Risk**

Naphthalene pesticide products are not registered for occupational use
and, therefore, occupational exposure to the pesticidal uses of
naphthalene is not anticipated and has not been assessed.

e.  **Ecological Risk**

[Birds, Terrestrial-phase amphibians, and Reptiles]{.underline}

Based on a screening-level assessment, naphthalene may pose an acute
risk to birds, terrestrial-phase amphibians and reptiles. The ecological
assessment was conducted with conservative use assumptions: six
applications per year were assumed, the highest application rate was
used (10.8 lbs ai/A, although some products are labeled for use at 0.56
lbs ai/A), and the model did not account for volatilization.
Furthermore, animal repellant products are formulated as flakes and
granules, but the assessment was conducted for granules only due to
modeling limitations. While there is some potential for a bird to
accidentally ingest a granule of naphthalene during gritting activities,
it is unlikely that a bird would consume naphthalene in flake form. The
modeling limitations, the conservative assumptions, and the uncertainty
surrounding volatility may have resulted in an over-estimate of risk.
Based on the conservative nature of the risk assessment and the fact
that naphthalene is a bird repellant, the Agency does not anticipate a
risk of concern and is not requiring mitigation measures for the
naphthalene animal repellent products.

[Mammals]{.underline}

When marketed as a rabbit repellent, the use directions instruct the
user to place the product in small bands around ornamentals; this use is
limited to small areas during the growing season. While the acute risk
estimates to terrestrial mammals exceed the Agency's LOCs, as for birds,
the assessment was highly conservative and may have over-estimated risk.
In addition, the incident data show very little history of pet exposure.
The Agency does not anticipate risk of concern to mammals from the
outdoor uses of naphthalene, based on the use pattern (localized
treatments around ornamentals as an animal repellant), and is not
requiring mitigation.

[Aquatic Organisms]{.underline}

Acute risk is not expected for freshwater animals, aquatic-phase
amphibians and aquatic nonvascular plants, and therefore, no mitigation
is required.

[Non-Target Insects and Plants]{.underline}

Due to lack of toxicity data, risks to honey bees and to terrestrial and
aquatic vascular plants can not be quantified; however, given its method
of application and use as a repellent around gardens, effect on insects
and plants are not anticipated.

[]{#__RefHeading___Toc213557908 .anchor}**2. Endocrine Disruptor
Effects**

Following recommendations of its Endocrine Disruptor Screening and
Testing Advisory Committee (EDSTAC), EPA determined that there was a
scientific basis for including, as part of the program, the androgen and
thyroid hormone systems, in addition to the estrogen hormone system. EPA
also adopted EDSTAC's recommendation that EPA include evaluations of
potential effects in wildlife. For pesticides, EPA will use FIFRA, and
to the extent that effects in wildlife may help determine whether a
substance may have an effect in humans, FFDCA authority to require the
wildlife evaluations. As the science develops and resources allow,
screening of additional hormone systems may be added to the Endocrine
Disruptor Screening Program (EDSP).

When the appropriate screening and/or testing protocols being considered
under the EDSP have been developed, individual pesticides may be subject
to additional screening and/or testing to better characterize effects
related to possible endocrine disruption.

[]{#__RefHeading___Toc213557909 .anchor}**3. Endangered Species**

The Endangered Species Act required federal agencies to ensure that
their actions are not likely to jeopardize listed species or adversely
modify designated critical habitat. The Agency has developed the
Endangered Species Protection Program to identify pesticides whose use
may cause adverse impacts on federally listed endangered and threatened
species, and to implement mitigation measures that address these
impacts. A determination that there is a likelihood of potential effects
to a listed species may result in limitations on the use of the
pesticide, other measures to mitigate any potential effects, and/or
consultations with the Fish and Wildlife Service or National Marine
Fisheries Service, as necessary.

Number range CHAPTER For naphthalene, the acute risk to birds,
terrestrial-phase amphibians and reptiles, and mammals exceed the
endangered species LOC, and therefore there is a potential for direct
effect to these taxa. In addition, there is a potential for indirect
effects to species that depend on them. The data are currently
insufficient to determine if there is a potential for direct or indirect
effect to terrestrial or aquatic plants. Naphthalene is not likely to
affect aquatic animals (fish or invertebrates) directly; the potential
for indirect effects depends on whether naphthalene could affect
semi-aquatic or aquatic plants.

[]{#__RefHeading___Toc213557910 .anchor}**D. Labeling Requirements**

In order to be eligible for reregistration, various use and safety
information will be needed in the labeling of all end-use products
containing naphthalene. For the specific labeling statements, refer to
Section V of this RED document.

[]{#__RefHeading___Toc213557911 .anchor}**V. What Registrants Need to
Do**

The Agency has determined that products containing naphthalene are
eligible for reregistration provided that the required risk mitigation
measures, including product packaging, are adopted and label amendments
are made. The Agency intends to issue Data Call-In Notices (DCIs)
requiring generic and product-specific data. Generally, registrants will
have 90 days from receipt of a DCI to complete and submit response forms
or request time extension and/or waiver requests with a full written
justification. For product-specific data, the registrant will have eight
months to submit data. Table 13 describes the packaging requirements and
label amendments that the Agency is requiring for naphthalene products
to be eligible for reregistration.

[]{#__RefHeading___Toc213557912 .anchor}**A. Manufacturing Use
Products**

1.  []{#__RefHeading___Toc213557913 .anchor}**Additional Generic Data
    Requirements**

The generic data base supporting the reregistration of naphthalene for
currently registered uses has been reviewed and determined to be
substantially complete. However, the Agency intends to issue a DCI
requiring a confirmatory chamber study (Guideline 875.2500) to determine
levels of naphthalene in the air resulting from use of mothballs at the
maximum label rate. It is recommended that a study protocol be submitted
to the Agency for review and approval prior to the inception of the
study. The Agency does not currently anticipate requiring additional
generic data. Other entities are conducting ongoing naphthalene research
to address toxicology issues including:

-   More accurate assessment of species differences in metabolism and
    clearance of naphthalene.

-   Cell proliferation data to provide linkage to cytotoxicity.

-   DNA adduct and mutagenicity studies in relevant target tissues *in
    vivo* to confirm lack of direct DNA mutagenicity.

-   Physiologically Based Pharmacokinetic (PBPK) model under development
    (2-3 years rough estimate) to better support the mode of action, and
    to characterize species differences in metabolism, and address
    involvement of multiples enzymes and clearance in humans versus
    rodents. The PBPK model may provide a more accurate determination of
    a human equivalent dose to be used in inhalation risk assessment.

These data will be included in future assessments of naphthalene.

[]{#__RefHeading___Toc213557914 .anchor}**2. Labeling for
Manufacturing-Use Products**

To ensure compliance with FIFRA, manufacturing-use product (MUP)
labeling should be revised to comply with all current EPA regulations,
PR Notices, and applicable policies. The MUP labeling should bear the
labeling contained in Table 13.

[]{#__RefHeading___Toc213557915 .anchor}**B. End-Use Products**

[]{#__RefHeading___Toc213557916 .anchor}**1. Additional Product-Specific
Data Requirements**

Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed
product-specific data regarding the pesticide after a determination of
eligibility has been made. The Registrant must review previous data
submissions to ensure that they meet current EPA acceptance criteria and
if not, commit to conduct new studies. If a registrant believes that
previously submitted data meet current testing standards, then the study
MRID numbers should be cited according to the instructions in the
Requirement Status and Registrants Response Form provided for each
product. The Agency intends to issue a separate product-specific data
call-in (PDCI), outlining specific data requirements. For any questions
regarding the PDCI, please contact Veronica Dutch at 703-308-8585.

[]{#__RefHeading___Toc213557917 .anchor}**2. Labeling for End-Use
Products**

To be eligible for reregistration, labeling changes are necessary to
implement measures outlined in Section IV above. Specific language to
incorporate these changes is specified in Table 13. Generally,
conditions for the distribution and sale of products bearing old
labels/labeling will be established when the label changes are approved.
However, specific existing stocks time frames will be established
case-by-case, depending on the number of products involved, the number
of label changes, and other factors.

[]{#__RefHeading___Toc213557918 .anchor}**C. Labeling Changes Summary
Table**

For naphthalene to be eligible for reregistration all naphthalene
mothball products must be packaged, and labels must be amended to
incorporate the risk mitigation measures, as outlined in Section IV.
Table 13 describes the packaging requirements and how language on the
labels should be amended.

+------------------+--------------------------------+-----------------+
| **Table 13.      |                                |                 |
| Summary of       |                                |                 |
| Labeling Changes |                                |                 |
| for              |                                |                 |
| Naphthalene**    |                                |                 |
+==================+================================+=================+
| **Description**  | **Amended Labeling Language**  | **Placement on  |
|                  |                                | Label**         |
+------------------+--------------------------------+-----------------+
| **Manufacturing  |                                |                 |
| Use Products**   |                                |                 |
+------------------+--------------------------------+-----------------+
| For All          | "Only for formulation into an  | Directions for  |
| Manufacturing    | ***insecticide/repellent***    | use             |
| Use Products     | for the following use(s)       |                 |
|                  | \[fill blank only with those   |                 |
|                  | uses that are being supported  |                 |
|                  | by MP registrant\]."           |                 |
|                  |                                |                 |
|                  | *Note to registrant:*          |                 |
|                  |                                |                 |
|                  | Special packaging for moth     |                 |
|                  | repellant end use products are |                 |
|                  | required to reduce the risk    |                 |
|                  | that children will ingest the  |                 |
|                  | product.                       |                 |
+------------------+--------------------------------+-----------------+
| For              | *Note to registrant:*          | Directions for  |
| Manufacturing    |                                | use             |
| Use Products     | After September 30, 2013       |                 |
| Formulated as    | formulation into loose         |                 |
| Indoor Use Moth  | mothball products is not       |                 |
| Repellant        | permitted. See End Use Product |                 |
| Products         | requirements for a description |                 |
|                  | of approved indoor moth        |                 |
|                  | repellant formulation types    |                 |
|                  | and packaging specifications.  |                 |
+------------------+--------------------------------+-----------------+
| One of these     | "This product may be used to   | Directions for  |
| statements may   | formulate products for         | Use             |
| be added to a    | specific use(s) not listed on  |                 |
| label to allow   | the MP label if the            |                 |
| reformulation of | formulator, user group, or     |                 |
| the product for  | grower has complied with U.S.  |                 |
| a specific use   | EPA submission requirements    |                 |
| or all           | regarding support of such      |                 |
| additional uses  | use(s)."                       |                 |
| supported by a   |                                |                 |
| formulator or    |                                |                 |
| user group       |                                |                 |
+------------------+--------------------------------+-----------------+
| Environmental    | "ENVIRONMENTAL HAZARDS"        | Precautionary   |
| Hazards          |                                | Statements:     |
| Statements       | "Do not discharge effluent     | Environmental   |
|                  | containing this product into   | Hazards         |
|                  | lakes, streams, ponds,         |                 |
|                  | estuaries, oceans, or other    |                 |
|                  | waters unless in accordance    |                 |
|                  | with the requirements of a     |                 |
|                  | National Pollutant Discharge   |                 |
|                  | Eliminations System (NPDES)    |                 |
|                  | permit and the permitting      |                 |
|                  | authority has been notified in |                 |
|                  | writing prior to discharge. Do |                 |
|                  | not discharge effluent         |                 |
|                  | containing this product to     |                 |
|                  | sewer systems without          |                 |
|                  | previously notifying the local |                 |
|                  | sewage treatment plant         |                 |
|                  | authority. For guidance,       |                 |
|                  | contact your State Water Board |                 |
|                  | or Regional Office of the      |                 |
|                  | Environmental Protection       |                 |
|                  | Agency."                       |                 |
+------------------+--------------------------------+-----------------+
| **End-Use        |                                |                 |
| Products**       |                                |                 |
+------------------+--------------------------------+-----------------+
| Availability     | "IMPORTANT: Keep out of reach  | Directions for  |
| Statements       | of children."                  | Use             |
|                  |                                |                 |
|                  | "Do not place in areas         |                 |
|                  | accessible to children."       |                 |
+------------------+--------------------------------+-----------------+
| Indoor Moth      | "IMPORTANT: It is illegal to   | Directions for  |
| Repellant Sachet | sell the sachets               | Use             |
| Products         | individually."                 |                 |
|                  |                                |                 |
|                  | "Do not open sachets."         |                 |
+------------------+--------------------------------+-----------------+
| For End Use      | *Note to registrant:*          | Directions for  |
| Products         |                                | use             |
| Formulated as    | After September 30, 2013,      |                 |
| Indoor Use Moth  | naphthalene may no longer be   |                 |
| Repellant        | formulated into loose mothball |                 |
| Products         | products unless contained in   |                 |
|                  | sachets meeting the following  |                 |
|                  | minimum manufacturing          |                 |
|                  | specifications:                |                 |
|                  |                                |                 |
|                  |   -------                      |                 |
|                  | ----- ----------- ------------ |                 |
|                  |   **P                          |                 |
|                  | hysical   **Minimum   **Test** |                 |
|                  |   Property**   Value**         |                 |
|                  |                                |                 |
|                  |   Tear                         |                 |
|                  |         2.2 lbs     ASTM D1004 |                 |
|                  |   Ini                          |                 |
|                  | tiation               Standard |                 |
|                  |   Machin                       |                 |
|                  | e                  Test Method |                 |
|                  |   Dir                          |                 |
|                  | ection                for Tear |                 |
|                  |                                |                 |
|                  |                     Resistance |                 |
|                  |                                |                 |
|                  |                        (Graves |                 |
|                  |                                |                 |
|                  |                       Tear) of |                 |
|                  |                                |                 |
|                  |                   Plastic Film |                 |
|                  |                                |                 |
|                  |                   and Sheeting |                 |
|                  |                                |                 |
|                  |   Tear                         |                 |
|                  |         2.2 lbs     ASTM D1004 |                 |
|                  |   Initiation                   |                 |
|                  |   Transverse                   |                 |
|                  |   Direction                    |                 |
|                  |                                |                 |
|                  |   Tensi                        |                 |
|                  | le      16,3000 psi ASTM D882A |                 |
|                  |   Str                          |                 |
|                  | ength                 Standard |                 |
|                  |   Machin                       |                 |
|                  | e                  Test Method |                 |
|                  |   Direct                       |                 |
|                  | ion                for Tensile |                 |
|                  |                                |                 |
|                  |                     Properties |                 |
|                  |                                |                 |
|                  |                        of Thin |                 |
|                  |                                |                 |
|                  |                        Plastic |                 |
|                  |                                |                 |
|                  |                       Sheeting |                 |
|                  |                                |                 |
|                  |   Tensi                        |                 |
|                  | le      20,000 psi  ASTM D882A |                 |
|                  |   Strength                     |                 |
|                  |   Transverse                   |                 |
|                  |   Direction                    |                 |
|                  |                                |                 |
|                  |   Heat                         |                 |
|                  | Seal    500 g/in    285° F, 40 |                 |
|                  |   Stren                        |                 |
|                  | gth                 PSI, 1 sec |                 |
|                  |                                |                 |
|                  |                     HS/HS heat |                 |
|                  |                                |                 |
|                  |                   seal side to |                 |
|                  |                                |                 |
|                  |                      heat seal |                 |
|                  |                                |                 |
|                  |                           side |                 |
|                  |   -------                      |                 |
|                  | ----- ----------- ------------ |                 |
|                  |                                |                 |
|                  | After September 30, 2013,      |                 |
|                  | naphthalene indoor moth        |                 |
|                  | repellant products formulated  |                 |
|                  | as cakes or blocks must have a |                 |
|                  | minimum diameter size of 2.5   |                 |
|                  | inches.                        |                 |
+------------------+--------------------------------+-----------------+
| Precautionary    | *Note to registrant:*          | Precautionary   |
| Statement for    |                                | Statements      |
| All Indoor Moth  | The following statement will   |                 |
| Repellant        | be placed within a shaded box  |                 |
| Products         | within the Precautionary       |                 |
|                  | Statements on the label. The   |                 |
|                  | coloring of the box and text   |                 |
|                  | will be such to provide a      |                 |
|                  | contrasting color to other     |                 |
|                  | label text. The shaded box     |                 |
|                  | must contain the following:    |                 |
|                  |                                |                 |
|                  | "**Keep out of reach of        |                 |
|                  | children.** Do not place in    |                 |
|                  | areas accessible to children." |                 |
|                  |                                |                 |
|                  | Include the following          |                 |
|                  | statement prominently on the   |                 |
|                  | front panel of product         |                 |
|                  | packaging (in bold), **"Keep   |                 |
|                  | out of reach of children."**   |                 |
+------------------+--------------------------------+-----------------+

  --------------------------------- --------------- ----------- ----------------------- ---------- -------------
  []{#__RefHeading___Toc213557919                                                                  
  .anchor}**Appendix A. Use                                                                        
  Patterns Eligible for                                                                            
  Reregistration for Naphthalene**                                                                 

  **Use Site**                      **Formulation   **Product   **Maximum Application   **Unit**   **Maximum
                                    Type**          Type**      Rate/Application^2^**              Retreatment
                                                                                                   Interval**

  Attics, Basements, Etc. (indoor   Crystalline     Flakes      1                       lb ai/400  7
  animal repellant use)                                                                 ft^3^ or   
                                                                                        oz ai/3    
                                                                                        ft^3^      

  Household/Domestic Dwellings      Crystalline     Balls,      0.37                    lb ai/12   7
  Contents                                          Flakes,                             ft^3^      
                                                    Sachets                                        

  Garden or House Perimeter         Crystalline     Granules,   0.014                   gal/ 1000  7
                                                    Flakes                              ft^2^      
  --------------------------------- --------------- ----------- ----------------------- ---------- -------------

+---------+---------+---+--------------------+-------+--------------------+
| []{     |         |   |                    |       |                    |
| #__RefH |         |   |                    |       |                    |
| eading_ |         |   |                    |       |                    |
| __Toc21 |         |   |                    |       |                    |
| 3557920 |         |   |                    |       |                    |
| .anc    |         |   |                    |       |                    |
| hor}**A |         |   |                    |       |                    |
| ppendix |         |   |                    |       |                    |
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+=========+=========+===+====================+=======+====================+
| *       |         |   |                    | **Use | **CITATION(S)**    |
| *REQUIR |         |   |                    | Patt  |                    |
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+---------+---------+---+--------------------+-------+--------------------+
| **New   | **Old   | * |                    |       |                    |
| Gu      | Gu      | * |                    |       |                    |
| ideline | ideline | S |                    |       |                    |
| N       | N       | t |                    |       |                    |
| umber** | umber** | u |                    |       |                    |
|         |         | d |                    |       |                    |
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|         |         | * |                    |       |                    |
|         |         | * |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.160 | D |                    | All   | 46862001           |
| 30.1600 |         | e |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | r |                    |       |                    |
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|         |         | a |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | U |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | e |                    |       |                    |
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|         |         | r |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | d |                    |       |                    |
|         |         | u |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | t |                    |       |                    |
|         |         | h |                    |       |                    |
|         |         | e |                    |       |                    |
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|         |         | r |                    |       |                    |
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|         |         | u |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | t |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.162 | D |                    | All   | 43112501           |
| 30.1620 |         | e |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | r |                    |       |                    |
|         |         | i |                    |       |                    |
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|         |         | i |                    |       |                    |
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|         |         | d |                    |       |                    |
|         |         | u |                    |       |                    |
|         |         | c |                    |       |                    |
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|         |         | o |                    |       |                    |
|         |         | n |                    |       |                    |
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|         |         | r |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | s |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.165 | F |                    |       | 46862001           |
| 30.1650 |         | o |                    |       |                    |
|         |         | r |                    |       |                    |
|         |         | m |                    |       |                    |
|         |         | u |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | a |                    |       |                    |
|         |         | t |                    |       |                    |
|         |         | i |                    |       |                    |
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|         |         | r |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | s |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.167 | F |                    | All   | 46862001           |
| 30.1670 |         | o |                    |       |                    |
|         |         | r |                    |       |                    |
|         |         | m |                    |       |                    |
|         |         | a |                    |       |                    |
|         |         | t |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | n |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | f |                    |       |                    |
|         |         | I |                    |       |                    |
|         |         | m |                    |       |                    |
|         |         | p |                    |       |                    |
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|         |         | t |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | s |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.170 | P |                    | All   | 43170801           |
| 30.1700 |         | r |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | m |                    |       |                    |
|         |         | i |                    |       |                    |
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|         |         | a |                    |       |                    |
|         |         | r |                    |       |                    |
|         |         | y |                    |       |                    |
|         |         | A |                    |       |                    |
|         |         | n |                    |       |                    |
|         |         | a |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | y |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | s |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 158.180 | A |                    | All   | 46862001           |
| 30.1800 |         | n |                    |       |                    |
|         |         | a |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | y |                    |       |                    |
|         |         | t |                    |       |                    |
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|         |         | o |                    |       |                    |
|         |         | d |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | N/A     | U |                    | All   | Data Gap           |
| 30.7050 |         | V |                    |       |                    |
|         |         | / |                    |       |                    |
|         |         | V |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | s |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | b |                    |       |                    |
|         |         | l |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | A |                    |       |                    |
|         |         | b |                    |       |                    |
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|         |         | i |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | n |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 63-11   | P |                    | All   | 42335803           |
| 30.7550 |         | a |                    |       |                    |
|         |         | r |                    |       |                    |
|         |         | t |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | t |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | n |                    |       |                    |
|         |         | C |                    |       |                    |
|         |         | o |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | f |                    |       |                    |
|         |         | f |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | c |                    |       |                    |
|         |         | i |                    |       |                    |
|         |         | e |                    |       |                    |
|         |         | n |                    |       |                    |
|         |         | t |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| **ECO   |         |   |                    |       |                    |
| LOGICAL |         |   |                    |       |                    |
| EF      |         |   |                    |       |                    |
| FECTS** |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 71-1    |   | Avian Acute Oral   | A, B  | 148176             |
| 50.2100 |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 71-2    |   | Avian Dietary      | A, B  | 00148175           |
| 50.2200 |         |   | Toxicity - Quail   |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 72-1    |   | Freshwater Fish    | A, B  | 45030801, 44302701 |
| 50.1075 |         |   | Acute Toxicity     |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 72-2    |   | Invertebrate       | A, B  | 44302702           |
| 50.1010 |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 72-4a   |   | Freshwater Fish    | A, B  | 46220970           |
| 50.1400 |         |   | Early Life- Stage  |       |                    |
|         |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| **TOXIC |         |   |                    |       |                    |
| OLOGY** |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-1    |   | Acute Oral         | A, B  | 00148174, 257224   |
| 70.1100 |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-2    |   | Acute Dermal       | A, B  | 00148409, 257229   |
| 70.1200 |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-3    |   | Acute Inhalation   | A, B  | 00144557, 257902   |
| 70.1300 |         |   | Toxicity           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-4    |   | Primary Eye        | A, B  | 00148408, 257228   |
| 70.2400 |         |   | Irritation         |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-5    |   | Primary Dermal     | A, B  | 00148177, 257227   |
| 70.2500 |         |   | Irritation         |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 81-6    |   | Dermal             | A, B  | 00148173           |
| 70.2600 |         |   | Sensitization      |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Acute              | A, B  | 44282801           |
| ideline |         |   | Neurotoxicity --   |       |                    |
|         |         |   | Rat                |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 82-3    |   | 90-Day Dermal --   | A, B  | 40021801           |
| 70.3250 |         |   | Rodent             |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 82-4    |   | 90-Day             | A, B  | 42835901           |
| 70.3465 |         |   | Inhalation - Rat   |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | 90-Day             | A, B  | 44856401           |
| ideline |         |   | Neurotoxicity --   |       |                    |
|         |         |   | Mammal             |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Oncogenicity --    | A, B  | 45630101           |
| ideline |         |   | Rat                |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Oncogenicity --    | A, B  | 42458301           |
| ideline |         |   | Mouse              |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 83-3    |   | Teratogenicity -   | A,B   | 42195401, 00157145 |
| 70.3700 |         |   | Rabbit             |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 83-3    |   | Prenatal           | A, B  | NTP 1991           |
| 70.3700 |         |   | Developmental --   |       |                    |
|         |         |   | Rat                |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 83-3    |   | Prenatal           | A, B  | NTP 1992           |
| 70.3700 |         |   | Developmental --   |       |                    |
|         |         |   | Rabbit             |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | Gene Mutation --   | A, B  | 42071601           |
| 70.5100 |         |   | Ames               |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Genotoxicity       | A, B  | 42071604           |
| ideline |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | Structural         | A, B  | 42071603           |
| 70.5300 |         |   | Chromosome         |       |                    |
|         |         |   | Aberration         |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | UDS Assay          | A, B  | 42071604           |
| 70.5550 |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | CHO Chromosome     | A, B  | NTP 2000           |
| 70.5375 |         |   | Aberration         |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | CHO Sister         | A, B  | NTP 2000           |
| 70.5375 |         |   | Chromatid Exchange |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 82-7    |   | Acute              | A, B  | 44282801           |
| 70.6200 |         |   | Neurotoxicity      |       |                    |
|         |         |   | (Oral) -- Rat      |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | *In Vivo* Mouse    | A, B  | 42071603           |
| 70.5395 |         |   | Bone Marrow        |       |                    |
|         |         |   | Micronucleus       |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 84-2    |   | Gene Mutation in   | A, B  | 42071602           |
| 70.5265 |         |   | *S.typhimurium*    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 82-7    |   | Subchronic         | A, B  | 44856401           |
| 70.6200 |         |   | Neurotoxicity      |       |                    |
|         |         |   | (Inhalation) --    |       |                    |
|         |         |   | Rat                |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | 4-Week Inhalation  | A, B  | 42934901           |
| ideline |         |   | -- Rat             |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | 90-Day Oral        | A, B  | NTP 1980a          |
| ideline |         |   | Toxicity -- Rat    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | 90-Day Oral        | A, B  | NTP 1980b          |
| ideline |         |   | Toxicity -- B6C3F1 |       |                    |
|         |         |   | Mouse              |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | 90-Day Oral        | A, B  | Shopp et al. 1984  |
| ideline |         |   | Toxicity -- DC1    |       |                    |
|         |         |   | Mouse              |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Chronic Toxicity/  | A, B  | NTP 2000           |
| ideline |         |   | Carcinogenicity    |       |                    |
|         |         |   | (Chamber)          |       |                    |
|         |         |   | Inhalation -- Rat  |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Chronic            | A, B  | NTP 1992           |
| ideline |         |   | Toxici             |       |                    |
|         |         |   | ty/Carcinogenicity |       |                    |
|         |         |   | (Chamber)          |       |                    |
|         |         |   | Inhalation --      |       |                    |
|         |         |   | Mouse              |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| **OCC   |         |   |                    |       |                    |
| UPATION |         |   |                    |       |                    |
| AL/RESI |         |   |                    |       |                    |
| DENTIAL |         |   |                    |       |                    |
| EXP     |         |   |                    |       |                    |
| OSURE** |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| Non-gu  |         |   | Indoor Air         | A, B  | 43716501           |
| ideline |         |   | Monitoring         |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 133-4   |   | Inhalation         | A, B  | Data Gap           |
| 75.2500 |         |   | Exposure           |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| *       |         |   |                    |       |                    |
| *ENVIRO |         |   |                    |       |                    |
| NMENTAL |         |   |                    |       |                    |
| FATE**  |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 161-1   |   | Hydrolysis         | A, B  | 45346801           |
| 35.2120 |         |   |                    |       |                    |
+---------+---------+---+--------------------+-------+--------------------+
| 8       | 163-1   |   | Sediment and Soil  | A, B  | 45346801           |
| 35.1230 |         |   | Ads                |       |                    |
|         |         |   | orption/Desorption |       |                    |
+---------+---------+---+--------------------+-------+--------------------+

[]{#__RefHeading___Toc213557922 .anchor}**Appendix C. Technical Support
Documents**

Additional documentation in support of this RED is maintained in the OPP
docket, located in Room S-4400, One Potomac Yard (South Building), 1777
S. Crystal Drive, Arlington, VA. It is open Monday through Friday,
excluding legal holidays, from 8:30 am to 4 pm.

The risk assessments and other supporting documents for naphthalene are
available in the Public Docket, under docket number
[EPA-HQ-OPP-2008-0343](http://www.regulations.gov/search/search_results.jsp?sid=11D6809E5945&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&N=0&css=0&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055),
and on the Agency's web page,
[http://www.regulations.gov.](http://www.regulations.gov./) The docket
contains risk assessments and related documents as of November, 2008.

Technical support documents for the Naphthalene RED include the
following:

**Health Effects Documents**

1*. Phase 4 Amendment: Response to Comments in Reference to
"Naphthalene: HED Chapter for the Reregistration Eligibility Decision
Document (RED)*" dated August 22, 2008.

2\. *Naphthalene: Phase 4 Amendment: Response to Comments In Reference
to "Naphthalene: Occupational and Residential Exposure Assessment and
Recommendations for the Reregistration Eligibility Decision Document,*"
dated September 10, 2008.

3\. R*eview of Naphthalene Incident Reports,* dated June 25, 2007.

**Ecological Fate and Effects Documents**

1\. *Revised Drinking Water Exposure Assessment for the Human Health
Risk Assessment for the Reregistration Decision Eligibility (RED) of
Naphthalene Incorporating the Registrant's Error Correction Comments,*
dated April 9, 2008.

2*. Revised Ecological Risk Assessment for Reregistration Eligibility
Decision (RED) for Naphthalene,* dated April 21, 2008.

[]{#__RefHeading___Toc213557923 .anchor}**Appendix D. Citations
Considered to be Part of the Database Supporting the Reregistration
Decision (Bibliography)**

**[GUIDE TO APPENDIX D]{.underline}**

1\. CONTENTS OF BIBLIOGRAPHY. This bibliography contains citations of
all studies considered relevant by EPA in arriving at the positions and
conclusions stated elsewhere in the Reregistration Eligibility Document.
Primary sources for studies in this bibliography have been the body of
data submitted to EPA and its predecessor agencies in support of past
regulatory decisions. Selections from other sources including the
published literature, in those instances where they have been
considered, are included.

2\. UNITS OF ENTRY. The unit of entry in this bibliography is called a
\"study\". In the case of published materials, this corresponds closely
to an article. In the case of unpublished materials submitted to the
Agency, the Agency has sought to identify documents at a level parallel
to the published article from within the typically larger volumes in
which they were submitted. The resulting \"studies\" generally have a
distinct title (or at least a single subject), can stand alone for
purposes of review and can be described with a conventional
bibliographic citation. The Agency has also attempted to unite basic
documents and commentaries upon them, treating them as a single study.

3\. IDENTIFICATION OF ENTRIES. The entries in this bibliography are
sorted numerically by Master Record Identifier, or \"MRID" number. This
number is unique to the citation, and should be used whenever a specific
reference is required. It is not related to the six-digit \"Accession
Number\" which has been used to identify volumes of submitted studies
(see paragraph 4(d)(4) below for further explanation). In a few cases,
entries added to the bibliography late in the review may be preceded by
a nine character temporary identifier. These entries are listed after
all MRID entries. This temporary identifying number is also to be used
whenever specific reference is needed.

4\. FORM OF ENTRY. In addition to the Master Record Identifier (MRID),
each entry consists of a citation containing standard elements followed,
in the case of material submitted to EPA, by a description of the
earliest known submission. Bibliographic conventions used reflect the
standard of the American National Standards Institute (ANSI), expanded
to provide for certain special needs.

a Author. Whenever the author could confidently be identified, the
Agency has chosen to show a personal author. When no individual was
identified, the Agency has shown an identifiable laboratory or testing
facility as the author. When no author or laboratory could be
identified, the Agency has shown the first submitter as the author.

b\. Document date. The date of the study is taken directly from the
document. When the date is followed by a question mark, the
bibliographer has deduced the date from the evidence contained in the
document. When the date appears as (1999), the Agency was unable to
determine or estimate the date of the document.

c\. Title. In some cases, it has been necessary for the Agency
bibliographers to create or enhance a document title. Any such editorial
insertions are contained between square brackets.

d\. Trailing parentheses. For studies submitted to the Agency in the
past, the trailing parentheses include (in addition to any
self-explanatory text) the following elements describing the earliest
known submission:

\(1\) Submission date. The date of the earliest known submission appears
immediately following the word \"received.\"

\(2\) Administrative number. The next element immediately following the
word \"under\" is the registration number, experimental use permit
number, petition number, or other administrative number associated with
the earliest known submission.

\(3\) Submitter. The third element is the submitter. When authorship is
defaulted to the submitter, this element is omitted.

(4) Volume Identification (Accession Numbers). The final element in the
    trailing parentheses identifies the EPA accession number of the
    volume in which the original submission of the study appears. The
    six-digit accession number follows the symbol \"CDL,\" which stands
    for \"Company Data Library.\" This accession number is in turn
    followed by an alphabetic suffix which shows the relative position
    of the study within the volume.

  ----------- -----------------------------------------------------------
  **MRID**    **Citation Reference**

              

  4898        Means, R.G. (1973) Preliminary evaluation of the
              effectiveness of Mosquito Beater\^(R)I, a granular
              repellent, against mosquitoes and blackflies. Mosquito News
              33(4):542-545. (Also\~In\~unpub- lished submission received
              Jul 16, 1975 under 4-123; submitted by Bonide Chemical Co.,
              Inc., Yorkville, N.Y.; CDL:126291-A)

  4900        Nowak, L.M. (1975) Interim Material Safety Data Sheet for
              Naphtha- lene. (Unpublished study received May 6, 1977
              under unknown admin. no.; prepared by Ashland Oil, Inc.,
              submitted by Kenova Chemical Co., St. Louis, Mo.;
              CDL:229765-A)

  4901        Samuel J. Milazzo Manufacturing Company (1967) Ten Day Test
              for Milazzo Company Animal Chaser. (Unpublished study
              received Sep 12, 1967 under 8218-1; prepared in cooperation
              with United States Testing Co., Inc. and Hermel
              Exterminating; CDL:224446-A)

  4902        Hunsberger, J.F. (1969) Testing Program. (Unpublished study
              re- ceived Oct 28, 1969 under 8218-1; prepared by Allentown
              Testing Laboratories, Inc., submitted by Samuel J. Milazzo
              Co., Pitts- ton, Pa.; CDL:224446-B)

  4903        Niper, R. (1963) Milazzo Brand Animal Chaser Test No. 1.
              (Unpub- lished study including letter dated Dec 9, 1963
              from R. Niper to Samuel J. Milazzo, received Dec 17, 1963
              under 8218-1; prepared by Monroe County Society for the
              Prevention of Cruelty to Ani- mals, submitted by Samuel J.
              Milazzo Co., Pittston, Pa.; CDL: 224446-C)

  4904        Uni-Research (1973) Evaluation of Dog Repellent Product:
              Technical Report. (Unpublished study received Dec 12, 1973
              under 1663-11; submitted by Grant Laboratories Div.,
              Oakland, Calif.; CDL: 022675-A)

  4906        Taylor, R.E. (1974) Acute Oral Toxicity (LDI50\^).
              (Unpublished study received Feb 26, 1974 under 779-29;
              prepared by Harris Laboratories, Inc., submitted by Faesy &
              Besthoff, Inc., Edge- water, N.J.; CDL:050215-A)

  4907        Harmad Laboratories (1976) Use of Naphthalene as an
              Insecticide in Controlling Lice and Fleas. (Unpublished
              study received Nov 16, 1976 under 1548-3; submitted by
              Vermex Co., Calabasas, Calif.; CDL:227450-A)

  4908        Harmad Laboratories (1976) Use of Naphthalene as an
              Insecticide in Controlling Mites. (Unpublished study
              received Nov 16, 1976 un- der 1548-3; submitted by Vermex
              Co., Calabasas, Calif.; CDL: 227450-B)

  4909        Harmad Laboratories (1976) Use of Naphthalene as a General
              Insect- icide. (Unpublished study received Nov 16, 1976
              under 1548-3; submitted by Vermex Co., Calabasas, Calif.;
              CDL:227450-C)

  4911        Whitmire, H.E. (1958) Fly Larvicide Test Reports Made on
              Cubetoid (L.L.) Liquid Larvicide Concentrate. (Unpublished
              study re- ceived Jan 16, 1958 under 499-110; submitted by
              Whitmire Re- search Laboratories, Inc., St. Louis, Mo.;
              CDL:228313-A)

  4912        Gerade, H.W. (19??) Di- and Tricyclic aromatic
              hydrocarbons. Pages 216-232,\~In\~Toxicology & Biochemistry
              of Aromatic Hydrocarbons. N.P. (Also\~In\~unpublished
              submission received Jun 22, 1965 under 862-EX-4; submitted
              by Sun Oil Co. of Pa., Philadelphia, Pa.; CDL:123931-A)

  4913        Sun Oil Company of Pennsylvania (1959?) Toxicity of
              Naphthalene. (Unpublished study received Jun 2, 1965 under
              862-EX-3; CDL: 123930-A)

  4914        Hamilton, D.W. (1964?) Results of Screening of Naphthalene,
              ENT No. 278 for Control of Third-Instar Japanese Beetle
              Grubs. (Un- published study received Sep 23, 1965 under
              862-EX-2; prepared by U.S. Agricultural Research Service,
              Entomology Research Div., Japanese Beetle Investigations,
              submitted by Sun Oil Co. of Pa., Philadelphia, Pa.;
              CDL:123929-B)

  5578        Coulter, JB. (1977) Field Trial Efficacy Test Evaluation
              Using Vermex as a control for Fleas, Sarcoptic Mange,
              Ticks. (Un- published study received Jun 2, 1977 under
              1548-3; prepared by Brownsville Animal Research Center for
              Harmad Laboratories; sub- mitted by Vermex Co., Calabasas,
              Calif.; CDL:230521-A)

  12997       Innis, Speiden & Company (1941) The Larvacide Log (August).
              New York: ISCO. (Also\~In\~unpublished submission received
              on unknown date under unknown admin. no.; submitted by E.J.
              Scarey, New York, N.Y.; CDL:222934-A)

  19056       Baker, R.S.; Holstun, J.T., Jr. (1965) Weed Control in
              Cotton on Tunica Clay: Line Project CR f1-19; Research
              Report CF-221. (Unpublished study received May 11, 1965
              under 100-549; prepared by Mississippi State Univ., Delta
              Branch Experiment Station in cooperation with U.S. Dept. of
              Agriculture, submitted by Ciba- Geigy Corp., Greensboro,
              N.C.; CDL:007072-AM)

  19915       Stout, D.M. (1964) (Efficacy of Cat Away as a Repellent).
              (Unpub- lished study received May 13, 1964 under 499-136;
              submitted by Whitmire Research Laboratories, Inc., St.
              Louis, Mo.; CDL: 020043-A)

  26091       Williamson, H.O.; McDuffie, W.E.; Jasper, R.L. (1972)
              (Grant\'s Napthalene: Toxicity to Rats). (U.S. Pharmacology
              Laboratory, unpublished report.)

  26232       Mississippi State University, Agricultural Experiment
              Station (1967) 1967 State Weed Committee Report: Weed
              Control Recommen- dations for Mississippi. State College,
              Miss.: MSU. (pp. 13, 24,48,50,54 only;
              also\~In\~unpublished submission received Oct 2, 1967 under
              8F0643; submitted by Stauffer Chemical Co., Westport,
              Conn.; CDL:091116-S)

  26929       Jasper, R.L. (1963) (Farnam Rotenox: Toxicity to Rats).
              (U.S. Pharmacology Laboratory, unpublished report.)

  32961       Brooks, D.M. (1959) Muskrat Damage: Prevention and Control.
              Indi- anapolis, Ind.: Indiana, Dept. of Conservation, Div.
              of Fish & Game. (Indiana W-2-R; also\~In\~unpublished
              submission received Oct 29, 1971 under 201-118; submitted
              by Shell Chemical Co., Washington, D.C.; CDL:000772-I)

  33603       Davis, C.S.; Deal, A.S.; Hart, W.H.; et al. (1967) Pest and
              Disease Control Program For Olives, 1967. ?: Univ. of
              California, Agricultural Experiment Station, Extension
              Service. (Also\~In\~ unpublished submission received Jul
              28, 1967 under 239-1839; submitted by Chevron Chemical Co.,
              Richmond, Calif.; CDL: 001386-A)

  44481       Ralston Purina Company (1968) Health Product Specification.
              (Un- published study received Dec 11, 1970 under 602-193;
              CDL: 004118-A)

  51053       Grant Laboratories (1964) ?Data on Grant\'s Dog
              Repellent\|. (Com- pilation; unpublished study received Jun
              5, 1964 under 1663-11; CDL:220938-A)

  51355       Unkel, M.W. (1962) Letter sent to C.C. McDonell dated Jan
              26, 1962 ?Lice-kill tests on birds\|. (Unpublished study
              received Jan 30, 1962 under unknown admin. no.; submitted
              by Hudson Associates, Inc., Hudson, Ohio; CDL:108791-A)

  53225       Strong Cobb Arner, Incorporated (1962) ?Effect of Pesticide
              Tablets on Chicken and Parakeets\|. (Unpublished study
              received Jan 30, 1962 under unknown admin. no.; submitted
              by Hudson Associates, Inc., Hudson, Ohio; CDL:108791-B)

  57823       Bottimer, L.J. (1929) Notes on Paradichlorobenzene and
              Naphthalene as repellents against clothes moth larvae.
              Journal of Economic Entomology 22(Jun):570-573.
              (Also\~In\~unpublished submission re- ceived May 25, 1977
              under 38510-1; submitted by Specialty Organ- ics, Inc.,
              Irwindale, Calif.; CDL:230291-A)

  59195       Mallis, A. (1961) Letter sent to Sam C. Billings dated May
              10, 1961 ?Results of studies on effect of PDB and
              Naphthalene against larvae of fabric insects\|.
              (Unpublished study received May 12, 1961 under unknown
              admin. no.; submitted by Gulf Re- search Development Co.,
              Pittsburgh, Pa.; CDL:228336-A)

  59196       Feldmesser, J. (1965) Letter sent to K. Deane Groves dated
              Aug 5, 1965 ?Results with Naphthalene in laboratory and
              greenhouse tests\|. (U.S. Agricultural Research Service,
              Crops Research Div.; unpublished study; CDL:123929-A)

  60828       Grant Laboratories (1964) ?Efficacy of Grant\'s Dog
              Repellent\|. (Reports by various sources; unpublished study
              received May 21, 1964 under 1663-11; CDL:220937-A)

  64153       Grant Laboratories (1964) ?Efficacy Studies on Dog
              Repellent\|. (Compilation; unpublished study received Jun
              25, 1964 under 1663-11; CDL:220938-A)

  65068       Brookes, P.; Lawley, P.D. (1964) Evidence for the binding
              of poly- nuclear aromatic hydrocarbons to the nucleic acids
              of mouse skin: Relation between carcinogenic power of
              hydrocarbons and their binding to deoxyribonucleic acid.
              Nature ?(May):782-784. (Published study)

  65069       Harvey, R.G.; Halonen, M. (1968) Interaction between
              carcinogenic hydrocarbons and nucleosides. Cancer Research
              28(Nov):2183- 2186. (Published study)

  65070       Peters, A.C.; Thake, D.C. (1980) Subchronic Toxicity Study:
              Naph- thalene (C52904), Fischer 344 Rats: Subcontract No.
              76-34- 106002. (Battelle; unpublished study)

  65071       Peters, A.C.; Thake, D.C. (1980) Subchronic Toxicity Study:
              Naph- thalene (C52904), B6C3F1 Mice: Subcontract No.
              76-34-106002. (Battelle; unpublished study)

  68188       Shell Chemical Company (1966) ?Efficacy of Various
              Rodenticides for Muskrats\|. (Compilation of published
              data; unpublished study received Oct 29, 1971 under
              201-118; CDL:227781-C)

  71774       Fletcher, D.W. (1980) Report to M & T Chemicals, Inc.:
              12-day Dietary LC50 Study with Biomet 300 in Bobwhite
              Quail: BLAL No. 80QC3. (Unpublished study, including
              sponsor\'s validation of feed levels report, R-1400-M,
              dated Jan 16, 1981, received Mar 26, 1981 under 5204-63;
              prepared by Bio-Life Associates, Ltd., submitted by M & T
              Chemicals, Inc., Rahway, N.J.; CDL: 244674-B)

  71775       Fletcher, D.W. (1980) Report to M & T Chemicals, Inc.:
              12-day Dietary LC50 Study with Biomet 300 in Mallard
              Ducklings: BLAL No. 80 DC 3. (Unpublished study, including
              sponsor\'s valida- tion of feed levels report, R-1400-M,
              dated Jan 16, 1981, received Mar 26, 1981 under 5204-63;
              prepared by Bio-Life Associates, Ltd., submitted by M & T
              Chemicals, Inc., Rahway, N.J.; CDL:244674-C)

  73787       Whitmire Research Laboratories, Incorporated (1964)
              ?Effectiveness of Outdoor Dog Away\|. (Compilation;
              unpublished study received Jun 11, 1964 under 499-138;
              CDL:020041-A)

  73788       Whitmire Research Laboratories, Incorporated (1964)
              ?Effectiveness of Indoor Dog Away\|. (Compilation;
              unpublished study received Jun 5, 1964 under 499-137;
              CDL:020042-A)

  77011       Statham, C.N.; Melancon, M.J., Jr.; Lech, J.J. (1976)
              Bioconcen- tration of xenobiotics in trout bile: A proposed
              monitoring aid for some waterborne chemicals. Science
              193(4254):680-681. (Al- so\~In\~unpublished submission
              received May 14, 1981 under 6704- 45; submitted by U.S.
              Dept. of Interior, Fish and Wildlife Serv- ice, Washington,
              D.C.; CDL:245185-E)

  89381       Moorefield, H.H. (1958) The Metabolism of 1-Naphthol (a
              Literature Review): IN-58-6. (Unpublished study received
              Jan 5, 1960 under PP0243; submitted by Union Carbide &
              Carbon Corp., New York, N.Y.; CDL:090270-D)

  123791      Williamson, H.; McDuffie, W.; Jasper, R. (1969) ?Swash
              Spray or Wash: Rat\|. (Unpublished study received Oct 22,
              1969 under 270- 40; prepared by Pharmacology Laboratory,
              submitted by U.S. Environmental Protection Agency,
              Beltsville, MD; CDL:118578-A)

  125145      Industrial Bio-Test Laboratories, Inc. (1970) Protocol for
              \...: Absorption of 14C-labeled Naphthalene in Albino Rats.
              (Unpub- lished study received Jun 1, 1970 under 0F0991;
              submitted by William Cooper & Nephews, Inc., Chicago, IL;
              CDL:093300-B)

  127315      Gallo, M.; Silver, E. (1983) Napthalene Toxicity: Summary
              and Doc- umentation. (Unpublished study received Mar 29,
              1983 under un- known admin. no.; prepared by UMDNJ-Rutgers
              Medical School, Dept. of Environmental and Community
              Medicine, submitted by Getty Refining and Marketing Co.,
              Tulsa, OK; CDL:249909-A)

  127316      Shrader, S. (1982) ?Study of the Chemical Napthalene
              P-20\|: SL \# 7155. (Unpublished study received Mar 29,
              1983 under unknown admin. no.; prepared by Shrader
              Analytical and Consulting Laboratories, Inc., submitted by
              Getty Refining and Marketing Co., Tulsa, OK; CDL:249909-B)

  127317      Herbes, S. (1981) Rates of microbial transformation of
              polycyclic aromatic hydrocarbons in water and sediments in
              the vicinity of a coal-coking wastewater discharge. Applied
              and Environmental Microbiology 41(1):20-28. (Also In
              unpublished submission re- ceived Mar 29, 1983 under
              unknown admin. no.; submitted by Getty Refining and
              Marketing Co., Tulsa, OK; CDL:249909-C)

  127318      Tattersfield, F. (1928) The decomposition of naphthalene in
              the soil and the effect upon its insecticidal action. Ann.
              Appl. Biol. XV:57-80. (Also In unpublished submission
              received Mar 29, 1983 under admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-D)

  127319      Fanburg, S. (1940) Exfoliative dermatitis due to
              naphthalene: Re- port of a eruption resembling mycosins
              fungoides. Archives of Dermatology and Syphilogy 42:53-58.
              (Also In unpublished sub- mission received Mar 29, 1983
              under unknown admin. no.; sub- mitted by Getty Refining and
              Marketing Co., Tulsa, OK; CDL: 249909-F)

  127320      Getty Refining and Marketing Co. (1979) Summary of
              Prechronic Studies ?of Naphthalene on Mice and Rats\|.
              (Unpublished study received Mar 29, 1983 under unknown
              admin. no.; CDL:249909-G)

  127321      Schmeltz, I.; Tosk, J.; Hilfrich, J.; et al. (1978)
              Bioassays of naphthalene and alkylnaphthalenes for
              co-carcinogenic activity: relation to tobacco
              carcinogenesis. Pages 47-60, In Carcino- genesis: Vol. 3:
              Polynuclear Aromatic Hydrocarbons. Edited by P. Jones and
              R. Freudenthal New York, NY; Raven Press. (Also In
              unpublished submission received Mar 29, 1983 under unknown
              admin. no.; submitted by Getty Refining and Marketing Co.,
              Tulsa, OK; CDL:249909-H)

  127322      Hardin, B.; Bond, G.; Sikov, M.; et al. (1981) Testing of
              selected workplace chemicals for teratogenic potential.
              Scand J work En- viron. Health 7(Suppl. 4):66-75. (Also In
              unpublished sub- mission received Mar 29, 1983 under
              unknown admin. no.; sub- mitted by Getty Refining and
              Marketing Co., Tulsa, OK; CDL: 249909-I)

  127323      Gatehouse, D. (1980) Mutagenicity of 1,2 ring-fused
              acenaphthenes against S. typhimurium TA1537 and TA1538:
              Structure-activity relationships. Mutation Research
              78:121-135. (Also In unpub- lished submission received Mar
              29, 1983 under unknown admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-K)

  127324      Kraemer, M.; Bimboes, D.; Greim, H. (1974) S. typhimurium
              and E. coli to Detect Chemical Mutagens. Taken from: Arch.
              Pharma- col. 284: R46. (Abstract; also In unpublished
              submission re- ceived Mar 29, 1983 under unknown admin.
              no.; submitted by Getty Refining and Marketing Co., Tulsa,
              OK; CDL:249909-L)

  127325      Ho, Y.; Ho, S. (1981) Screeinng of carcinogens with the
              prophage ?lambda\|cits 857 induction test. Cancer Research
              41(Feb):532- 536. (Also In unpublished submission received
              Mar 29, 1983 un- known admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-M)

  127326      Weeks, C.; Rao, T.; Young, J.; et al. (1979) Effect of
              weak-, non-, and co-carcinogenic chemicals on
              2-acetylaminofluorene-induced mutation in Salmonella
              typhimurium. Toxicology 14:255-262. (Also In unpublished
              submission received Mar 29, 1983 under un- known admin.
              no.; submitted by Getty Refining and Marketing Co., Tulsa,
              OK; CDL:249909-N)

  127327      Tonelli, Q.; Custer, R.; Sorof, S. (1979) Transformation of
              cul- tured mouse mammary glands by aromatic amines and
              amides and their derivatives. Cancer Research
              39(May):1784-1792. (Also In unpublished submission received
              Mar 29, 1983 under unknown admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-O)

  127328      Rhim, J.; Park, D.; Weisburger, E.; et al. (1974)
              Evaluation of an in vitro assay system for carcinogens
              based on prior infection of rodent cells with
              nontransforming RNA tumor virus. Journal of the National
              Cancer Institute 52(4):1167-1171. (Also In un- published
              submission received Mar 29, 1983 under unknown admin. no.;
              submitted by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-P)

  127329      Freeman, A.; Weisburger, E.; Weisburger, J.; et al. (1973)
              Trans- formation of cells cultures as an indication of the
              carcinogenic potential of chemicals. Journal of the
              National Cancer Insti- tute 51(3):799-807. (Also In
              unpublished submission received Mar 29, 1983 under unknown
              admin. no.; submitted by Getty Re- fining and Marketing
              Co., Tulsa, OK; CDL:249909-Q)

  127330      Moles, A.; Bates, S.; Rice, S.; et al. (1981) Reduced
              growth of co- ho salmon fry exposed to two petroleum
              components, toluene and naphthalene, in fresh water.
              Transactions of the American Fish- eries Society
              110:430-436. (Also In unpublished submission re- ceived Mar
              29, 1983 under unknown admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-R)

  127331      Korn, S.; Moles, D.; Rice, S. (1979) Effects of temperature
              on the median tolerance limit of pink salmon and shrimp
              exposed to toluene, naphthalene and Cook Inlet crude oil.
              Bull. Environm. Contam. Toxicol. 21:521-525. (Also In
              unpublished submission received Mar 29, 1983 under unknown
              admin. no.; submitted by Getty Refining and Marketing Co.,
              Tulsa, OK; CDL:249909-S)

  127332      Parkhurst, B.; Bradshaw, A.; Forte, J.; et al. (1981) The
              chronic toxicity of Daphnia magna of acridine, a
              representative azaarene present in synthetic fossil fuel
              products and wastewaters. Environmental Pollution, Series A
              24:21-30. (Also In unpub- lished submission received Mar
              29, 1983 under unknown admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-T)

  127333      Shichi, H.; Tanaka, M.; Jensen, N.; et al. (1980) Genetic
              differ- ences in cataract and other ocular abnormalities
              induced by paracetamol and naphthalene. Pharmacology
              20:229-241. (Also In unpublished submission received Mar
              29, 1983 under unknown admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-V)

  127334      Ghetti, G.; Mariani, L. (1956) Alterazioni oculari da
              naftalina. ?Eye changed due to naphthalene\|. Med. Lavoro
              47(10):533-538. (Italian text; also In unpublished
              submission received Mar 29, 1983 under unknown admin. no.;
              submitted by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-W)

  127335      Stokinger, H.; Mountain, J. (1963) Test for
              hypersusceptibility to hemolytic chemicals. Archives of
              Environmental Health 6(Apr): 495-502. (Also In unpublished
              submission received Mar 29, 1983 under unknown admin. no.;
              submitted by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-Y)

  127336      Valaes, T.; Doxiadis, S.; Fessas, P. (1963) Acute hemolysis
              due to napthalene inhalation. Journal of Pediatrics
              63(5):904-915. (Also In unpublished submission received Mar
              29, 1983 under un- known admin. no.; submitted by Getty
              Refining and Marketing Co., Tulsa, OK; CDL:249909-Z)

  127337      Tong, S.; Hirokata, Y.; Trush, M.; et al. (1981) Clara cell
              damage and inhibition of pulmonary mixed-function oxidase
              activity by naphthalene. Biochemical and Biophysical
              Research Communi- cations 100(3):944-950. (Also In
              unpublished submission re- ceived Mar 29, 1983 under
              unknown admin. no.; submitted by Getty Refining and
              Marketing Co., Tulsa, OK; CDL:249909-AA)

  127338      Mahvi, D.; Bank, H.; Harley, R. (1977) Morphology of
              naphtha- lene-induced bronchiolar lesion. American Journal
              of Pathology 86(3):559-572. (Also In unpublished submission
              received Mar 29, 1983 under unknown admin. no.; submitted
              by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-AB)

  127339      Wolf, O. (1978) Carcinoma of the larynx among Naphthalene
              Cleaners. A translation of: Larynxkarzinome bei
              Napthalinreinigern. Zeits. Ges. Hyg. 24:737-739.
              (Unpublished study received Mar 29, 1983 under unknown
              admin. no.; submitted by Getty Re- fining and Marketing
              Co., Tulsa, OK; CDL:249909-AC)

  127340      Anziulewicz, J.; Dick, H.; Chiarulli, E. (1959)
              Transplacental naphthalene poisoning. Amer. J. Obst.
              Gynecol. 78:519-521. (Also In unpublished submission
              received Mar 29, 1983 under un- known admin. no.; submitted
              by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-AD)

  127341      Harris, S.; Bond, G.; Niemeier, R. (1978) The Effects of
              2-Nitro- propane, Naphthalene, and Hexachlorobutadiene on
              Fetal Rat De- velopment. (Unpublished study received Mar
              29, 1983 under un- known admin. no.; prepared by U.S.
              National Institute for Occu- pational Safety and Health,
              submitted by Getty Refining and Marketing Co., Tulsa, OK;
              CDL:249909-AE)

  128368      US EPA (1981) Administrative Record of the Registration
              Standard for Naphthalene.

  138288      Tracor Jitco, Inc. (1979) Pesticide Chemical Use Pattern
              Profile for Naphthalene: 055801: Contract 68-01-4988.

  138289      U.S. Environmental Protection Agency (1979) EPA Index to
              Pesticide Chemicals: Naphthalene: 055801.

  138290      Scarato, R. (1981) Preliminary Quantitative Usage Analysis
              of Naph- thalene. Rev.

  144417      Texaco Inc. (19??) Description of Manufacturing Process
              \[and Pro- duct Chemistry: Napthalene\]. Unpublished study.
              8 p.

  144418      Texaco Inc. (19??) Declaration and Certification of
              Ingredients: \[Naphthalene\]. Unpublished study. 1 p.

  144419      Texaco Inc. (19??) Discussion on Formation of Unintentional
              Ingre- dients: \[Naphthalene\]. Unpublished study. 1 p.

  144556      Naismith, R. (1985) Repeated Dose Dermal Toxicity\--Rat: 28
              Day Dose Range Finding Study: \[5601-56-1\]: Study No. PH
              434-TX-001-85. Unpublished study prepared by Pharmakon
              Research International, Inc. 20 p.

  144557      Fait, D.; Nachreiner, D. (1985) Naphthalene: Acute
              Inhalation Tox- icity Study: \[Rats\]: Project Report
              48-511. Unpublished study prepared by Bushy Run Research
              Center. 30 p.

  148172      MacGregor, R. (1985) Bioassay Testing of Sample 5601-56-1
              in Fresh Water with the Lepomis macrochirus and Daphnia
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              in support of the RED for Feasy & Besthoff Rabbit & Dog
              Chaser. Transmittal of 1 study.

  42640001    Kuhn, J. (1993) Dermal Sensitization Study in Guinea Pigs:
              F&B Rabbit & Dog Chaser: Lab Project Number: 9647-92.
              Unpublished study prepared by Stillmeadow, Inc. 17 p.

  42835900    Recochem (1993) Submission of toxicity data in support of
              the registration standard for naphthalene. Transmittal of 1
              study.

  42835901    Coombs, D.; Kieran, P.; Hardy, C.; et al. (1993)
              Naphthalene: 13-Week Inhalation Study in Rats: Lab Project
              Number: LDA 2/930704. Unpublished study prepared by
              Huntingdon Research Centre Ltd. 218 p.

  42894000    Recochem (1993) Submission of product chemistry data in
              support of registration standard for naphthalene.
              Transmittal of 1 study.

  42894001    Kellenbenz, R. (1993) Discussion of Formation of
              Impurities: Naphthalene. Unpublished study prepared by
              Texaco Chemical Co. 7 p.

  42934900    Recochem (1993) Submission of Toxicology Data in Response
              to Requirements Status, Registrant\'s Response, and Data
              Call-in for Naphthalene. Transmittal of 1 study.

  42934901    Coombs, D. (1993) Naphthalene 4-Week Inhalation Study in
              Rats: Lab Project Number: LDA 1/921559. Unpublished study
              prepared by Huntingdon Research Centre Ltd. 165 p.

  43112500    Recochem Inc. (1994) Submittal of Product Chemistry Data in
              Support of Data Call-in for Naphthalene Registration
              Standard. Transmittal of 1 study.

  43112501    Fletcher, C. (1994) Description of Beginning Materials and
              Manufacturing Process: Unpublished study prepared by
              Recochem Inc. 12 p.

  43170800    Recochem Inc. (1994) Submission of Product Chemistry Data
              for Naphthalene (LX 1298-01) in Support of a Data Call-In
              Reregistration. Transmittal of 1 study.

  43170801    Mullee, D.; Bartlett, A. (1994) LX 1298-01 (Naphthalene):
              Preliminary Analysis: Lab Project Number: 486/007.
              Unpublished study prepared by Safepharm Labs. Ltd. 37 p.

  43224700    Dr. T\'s Nature Products Co., Inc. (1994) Submittal of
              Efficacy Data in Support of Registration of Dr. T\'s Rat
              Scat Rat and Mouse Repellent. Transmittal of 1 study.

  43224701    Scheiring, J. (1994) Dr. T\'s Rat Scat Rat and Mouse
              Repellent: Efficacy. Unpublished study prepared by Dept. of
              Biological Sciences, The University of Alabama. 26 p.

  43294600    Dr. T\'s Nature Products Co., Inc. (1994) Submission of
              efficacy data in support of the registration for Dr. T\'s
              Rat Scat Rat and Mouse Repellent. Transmittal of 1 study.

  43294601    Scheiring, J. (1994) DR. T\'s Rat Scat Rat and Mouse
              Repellent: Efficacy: Addendum to MRID No. 43224701.
              Unpublished study prepared by The University of Alabama. 38
              p.

  43375600    Faesy & Besthoff, Inc. (1994) Submittal of Supplemental
              Toxicity Data in Support of Registration for F&B Rabbit and
              Dog Chaser. Transmittal of 1 study.

  43375601    Kuhn, J. (1994) Dermal Sensitization study in Guinea Pigs:
              F&B Rabbit & Dog Chaser: Amendment: Lab Project Number:
              9647-92. Unpublished study prepared by Stillmeadow, Inc. 10
              p.

  43523300    Dragon Chemical Corp. (1995) Submission of toxicology data
              in support of RED for dried blood. Transmittal of 1 study.

  43523301    Kuhn, J. (1994) Acute Oral Toxicity Study in Rats: (F & B
              Rabbit and Dog Chaser): Final Report: Lab Project Number:
              1607-94. Unpublished study prepared by Stillmeadow, Inc. 11
              p.

  43716500    Recochem, Inc. (1995) Submission of Exposure and Reentry
              Protection Data in Support of the Registration Standard for
              Napthalene. Transmittal of 1 Study.

  43716501    Waggoner, T. (1994) Estimation of Homeowner Exposure to
              LX1298-01 (Napthalene) Resulting from Simulated Residential
              Use as an Insect Repellent: Final Report: Lab Project
              Number: 93-9083: 92-298-01-21H-02: 92-298-01-21H-03.
              Unpublished study prepared by Landis International, Inc.
              and Pharmaco LSR, Inc. 100 p.

  43765100    Dr. T\'s Nature Products Co., Inc. (1995) Submission of
              Efficacy Data in Support of the Registration of Dr. T\'s
              Snake-a-Way Snake Repellent. Transmittal of 2 Studies.

  43765101    Scheiring, J. (1995) Dr. T\'s Rat Scat Rat and Mouse
              Repellent: Efficacy: Edited Final Report. Unpublished study
              prepared by University of Alabama. 20 p.

  43765102    Scheiring, J. (1995) Dr. T\'s Rat Scat Rat and Mouse
              Repellent: Efficacy: Revised Final Report: (Includes Raw
              Data). Unpublished study prepared by University of Alabama.
              46 p.

  43874000    Faesy & Besthoff, Inc. (1995) Submission of Toxicity Data
              in Support of the RED for Dried Blood in F & B Rabbit & Dog
              Chaser. Transmittal of 1 Study.

  43874001    Bennick, J. (1995) F & B Rabbit and Dog Chaser: Acute
              Inhalation Toxicity Study in Rats: Final Report: Lab
              Project Number: 2376-95: S9-FF81-3. Unpublished study
              prepared by Stillmeadow, Inc. 10 p.

  44009800    Faesy & Besthoff, Inc. (1996) Submission of Pesticide Use
              Data in Support of Registration of F&B Rabbit and Dog
              Chaser. Transmittal of 1 Study.

  44009801    Fletcher, D. (1996) Captive Study for Efficacy of a
              Repellent in Outdoor Cats: F & B Rabbit and Dog Chaser: Lab
              Project Number: 95 CR-100. Unpublished study prepared by
              DWF Research. 198 p.

  44282800    Recochem, Inc. (1997) Submission of Toxicity Data in
              Support of the Naphthalene Registration Standard.
              Transmittal of 1 Study.

  44282801    Reynolds, S. (1997) Naphthalene: Neurotoxicity Study by a
              Single Oral Gavage Administration to CD Rats Followed by a
              14-Day Observation Period: Final Report: Lab Project
              Number: 96/1140: 96/RCE001/1140: RCE/001. Unpublished study
              prepared by Huntingdon Life Sciences Ltd. 383 p.

  44302700    Recochem, Inc. (1997) Submission of Hazard to Aquatic
              Organisms Data in Support the Naphthalene Registration
              Standard. Transmittal of 2 Studies.

  44302701    Kelly, C.; Thirkettle, K.; Smith, B. (1997) Naphthalene:
              Acute Toxicity to Bluegill Sunfish (Lepomis macrochirus):
              Lab Project Number: RCE 3/971511. Unpublished study
              prepared by Huntingdon Life Sciences, Ltd. 47 p.

  44302702    Kelly, C.; Thirkettle, K.; Smith, B. (1997) Naphthalene:
              Acute Toxicity to Daphnia magna: Lab Project Number: RCE
              4/971512. Unpublished study prepared by Huntingdon Life
              Sciences, Ltd. 41 p.

  44856400    Recochem, Inc. (1999) Submission of Toxicity Data in
              Support of the Reregistration of Napthalene. Transmittal of
              1 Study.

  44856401    Kenny, T. (1999) Naphthalene: Neurotoxicity Study by
              Inhalation Administration to CD Rats for 13 Weeks: Lab
              Project Number: RCE005/984517. Unpublished study prepared
              by Huntingdon Life Sciences, Ltd. 218 p.

  44898400    Bonide Products, Inc. (1999) Submission of Product
              Chemistry Data in Support of the Registration of Mosquito
              Beater. Transmittal of 1 Study.

  44898401    Krenick, F. (1992) Bonide Mosquito Beater, EPA Reg. No.
              4-123: The Repellent Effectiveness of Mosquito Beater
              Granules Against Adult Mosquitoes in an Urban Neighborhood.
              Unpublished study prepared by Bonide Products, Inc. 10 p.

  44914700    Laurence Finberg (1999) Submission of Toxicity Data Related
              to Adverse Effects of Naphthalene. Transmittal of 1 study.

  44914701    Finberg, L. (1999) Undated Letter Sent to D. Peacock:
              (Toxic and Mutagenic Effects of Napthalene Including
              Information of Human Anemia and G-6-PD Deficiency). 27 p.

  45030800    Recochem, Inc. (1999) Submission of Toxicity Data in
              Support of the Registration of Naphthalene Technical.
              Transmittal of 1 Study.

  45030801    Bell, G. (1999) Naphthalene: Acute Toxicity for Rainbow
              Trout (Oncorhynchus mykiss): Amended Final Report: Lab
              Project Number: LDA 013/994061. Unpublished study prepared
              by Huntingdon Life Sciences Ltd. 34 p.

  45346800    Recochem, Inc. (2001) Submission of Environmental Fate Data
              in Support of the Reregistration of Naphthalene.
              Transmittal of 1 Study.

  45346801    Hummel, R. (2001) Overview of the Environmental Fate of
              Naphthalene. Unpublished study prepared by Landis
              International, Inc. 318 p.

  45498500    Bonide Products, Inc. (2001) Submission of Product
              Chemistry Data in Support of the Registration of Mosquito
              Beater. Transmittal of 1 Study.

  45498501    Horton, R. (2001) Bonide Mosquito Beater Product Identity
              and Composition. Unpublished study prepared by Bonide
              Products, Inc. 16 p. {OPPTS 830.1550, 830.1600, 830.1670,
              830.1700, 830.1750, 830.1800, 830.6303, 830.6315, 830.6317,
              830.6320, 830.7000, 830.7300}

  45630100    Recochem, Inc. (2002) Submission of Toxicity and Fate Data
              in Support of the Reregistration of Naphthalene Technical.
              Transmittal of 1 Study.

  45630101    National Toxicology Program (2000) NTP Technical Report on
              the Toxicology and Carcinogenesis Studies of Naphthalene:
              Lab Project Number: NAPHTHALENE/NTP/TR/500: NTP TR 500.
              Unpublished study. 174 p.

  46233900    Bonide Products, Inc. (2004) Submission of Efficacy Data in
              Support of the Registration of Bonide Mosquito Beater.
              Transmittal of 1 Study.

  46233901    Paulson, S. (2004) Efficacy Testing of a Bonide Mosquito
              Beater. Unpublished study prepared by Virginia Polytechnic
              Inst. and State University. 10 p.

  46631200    I-Ching Chemical Co., Ltd. (2005) Submission of Product
              Chemistry Data in Support of the Application for
              Registration of I-Ching Naphthalene Moth Balls. Transmittal
              of 3 Studies.

  46631201    Chang, S. (2005) I-Ching Naphthalene Moth Balls - Product
              Chemistry. Unpublished study prepared by I-Ching Chemical
              Company, Ltd. 15 p.

  46631202    Chang, S. (2005) I-Ching Naphthalene Moth Balls - Product
              Chemistry. Project Number: 051260/1/5. Unpublished study
              prepared by I-Ching Chemical Company, Ltd. and New Jersey
              Laboratories, Inc. 37 p.

  46631203    Chang, S. (2005) Physical/Chemical Properties of I-Ching
              Naphthalene Moth Balls. Unpublished study prepared by
              I-Ching Chemical Co., Ltd. 6 p.

  46657700    I-Ching Chemical Company, Ltd. (2005) Submission of Product
              Chemistry Data in Support of the Application for
              Registration of I-Ching Naphthalene Moth Balls. Transmittal
              of 1 Study.

  46657701    Chang, S. (2005) Storage Stability of I-Ching Naphthalene
              Moth Balls. Project Number: NJL/051260/1/5. Unpublished
              study prepared by I-Ching Chemical Company, Ltd. and New
              Jersey Laboratories, Inc. 5 p.

  46700700    I-Ching Chemical Company, Ltd. (2005) Submission of Product
              Chemistry Data in Support of the Application for
              Registration of I-Ching Naphthalene Moth Balls. Transmittal
              of 2 Studies.

  46700701    Chang, S. (2005) I-Ching Naphthalene Moth Balls - Product
              Chemistry. Unpublished study prepared by I-Ching Chemical
              Company Ltd. 17 p.

  46700702    Chang, S. (2005) I-Ching Naphthalene Moth Balls - Product
              Chemistry. Project Number: 051260. Unpublished study
              prepared by I-Ching Chemical Company, Ltd. 37 p.

  46706900    I-Ching Chemical Company Ltd. (2005) Submission of Product
              Chemistry Data in Support of the Application for
              Registration of I-Ching Naphthalene Moth Balls. Transmittal
              of 1 Study.

  46706901    Chang, S. (2005) Physical/Chemical Properties of I-Ching
              Naphthalene Moth Balls. Unpublished study prepared by
              I-Ching Chemical Company, Ltd. 7 p.

  46746900    Dr. T\'s Nature Products, Inc. (2006) Submission of
              Efficacy Data in Support of the Registration of the
              Registration of Dr. T\'s Snake-A-Way Snake Repellent.
              Transmittal of 1 Study.

  46746901    Lillywhite, H. (1989) Dr. T\'s Original Snake-A-Way: Final
              Report. Project Number: C1/1989. Unpublished study prepared
              by University of Florida. 22 p.

  46778300    IMS Trading, LLC (2006) Submission of Product Chemistry
              Data in Support of the Application for Registration of IMS
              Old Fashion Moth Balls. Transmittal of 1 Study.

  46778301    Conti, J. (2006) Groups A & B \-- Product Chemistry:
              Naphthalene. Project Number: 983/002/02. Unpublished study
              prepared by Acta Group, L.L.C. 27 p.

  46862000    Oxford & Hill Home Products, LLC (2006) Submission of
              Product Chemistry Data in Support of the Application for
              Registration of Moth-Be-Gone Moth Balls 2. Transmittal of 1
              Study.

  46862001    Brookman, D. (2006) Product Properties - Group A:
              Moth-Be-Gone Moth Balls 2. Unpublished study prepared by
              Genesis Engineering & Redevelopment LLC. 17 p.

  46880900    U.S. Environmental Protection Agency (2006) Submission of
              Exposure and Risk Data. Transmittal of 5 Studies.

  46880903    Adgate, J.; Barr, D.; Clayton, C.; et al. (2001)
              Measurement of Children\'s Exposure to Pesticides: Analysis
              of Urinary Metabolite Levels in a Probability-Based Sample.
              Environmental Health Perspectives 109(6): 583-590.

  46905000    I-Ching Chemical Company (2006) Submission of Product
              Chemistry Data in Support of the Registration of I-Ching
              Naphthalene Moth Balls. Transmittal of 1 Study.

  46905001    Chang, S. (2005) Volume 5: Physical/Chemical Properties of
              I-Ching Naphthalene Moth Balls (Storage Stability Study:
              Final Report): Compilation of 3 Month, 6 Month, 9 Month and
              12 Month Storage Stability Data. Project Number: 061263,
              060001, 052033. Unpublished study prepared by I-Ching
              Chemical Company, Ltd. 62 p.

  47104500    Recochem, Inc. (2007) Submission of Toxicity Data in
              Support of the Reregistration of Naphthalene Technical.
              Transmittal of 1 Study.

  47104501    Tedesco, J. (2006) Naphthalene: In Vitro Dermal Absorbtion
              Rate Testing. Project Number: DUPONT/17707, 15939, 1623.
              Unpublished study prepared by Dupont Haskell Laboratory. 50
              p.

  47165200    Recochem, Inc. (2007) Submission of Efficacy Data in
              Support of the Registration of Naphthalene Technical.
              Transmittal of 1 Study.

  47165201    Daisy, B.; Strobel, G.; Castillo, U.; et. al. (2002)
              Naphthalene, An Insect Repellant, is Produced by Muscodor
              vitigenus, a Novel Endophytic Fungus. Microbiology 148:
              3737-3741

  47183900    Recochem (2007) Submission of Efficacy Data in Support of
              the Reregistration of Naphthalene Technical. Transmittal of
              1 Study.

  47183901    Small, G. (2006) Laboratory Bioassays to Assess the
              Efficacy of a Naphthalene Repellent Against the Clothes
              Moth, Tineola bisselliella. Project Number: NAPH/6/04,
              06/07. Unpublished study prepared by Insect Investigations
              Ltd. 22 p.

  47464900    I-Ching Chemical Company Ltd. (2008) Submission of Toxicity
              Data in Support of the Application for Registration of
              I-Ching Naphthalene Moth Balls. Transmittal of 9 Studies.

  47464901    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Prenatal Developmental Toxicity (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 7 p.

  47464902    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Reproduction and Fertility Effects (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 7 p.

  47464903    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Bacterial Reverse Mutation Assay (Referenced Data) .
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 6 p.

  47464904    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Genotoxicity in Human Lymphoblasts by Atmospheric
              Reaction Products of Naphthalene and Phenanthrene, Mutat
              Res 393(1-2):23-35. Unpublished study prepared by I-Ching
              Chemical Company, Ltd. 5 p.

  47464905    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls in Vitro Mammalian Cytogenetics (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 11 p.

  47464906    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Naphthalene Induced Chromosomal Aberrations in the
              Bone Marrow of the Test Species (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 7 p.

  47464907    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls. The Ability of Naphthalene to Induce Micronuclei in
              Polychromatic Erythrocytes (Referenced Data). Unpublished
              study prepared by I-Ching Chemical Company, Ltd. 8 p.

  47464908    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Subchronic Neurotoxicity (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 6 p.

  47464909    Chang, S. (2008) Toxicology of I-Ching Naphthalene Moth
              Balls Immunotoxicity of Naphthalene (Referenced Data).
              Unpublished study prepared by I-Ching Chemical Company,
              Ltd. 5 p.

  47466300    United States Environmental Protection Agency (2008)
              Submission of Fate, Residue, Exposure and Risk, Efficacy,
              and Toxicity Data in Support of Risk Assessment.
              Transmittal of 50 Studies.

  47466336    Reinert, J. (1983) Pesticides in the Indoor Environment.
              United States Environmental Agency. p. 233-238.
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