UNITED ST A TES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

MEMORANDUM Date: 24-AUG-2015 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

SUBJECT: d-Limoncnc. Registration Review Response to Comment

PC Code: 07970 I , 87970 I Decision No.: 506259 Petition No.: NA Risk Assessment Type: NA TXRNo.:NA MRID No.: NA
FROM: Monique M. Perron , Sc.D. DP Barcode: 427920 Registration No.: NA Regulatory Action: Registration R eview Case No.: 3083 CAS No.: 5989-27-5 40CFR: §180
.539 , §180.910 , §180
.930
Toxicologist, Risk Assessment Branch I (RABI) Health Effects Division (HED) (7509P) THROUGH: Thurston Morton , Acting Branch Chief

### /'?**d/;J~** RABI/HED (7509P) TO: Caitlin Newcamp Risk Management and Implementation Branch I Pesticide Re-evaluation Division (PRO) (7508P)
Attached is the HED ' s response to a comment for d-limonene (Comment ID : EPA-HQ-OPP20 I 0-0 I 17-0019) that was submitted by an anon y mous individual as part of the Registration Re view process. It should be noted that the comment was originally mislabeled with an incorrect docket number. The comment and HED ' s response are provided below
. 

### Co mment: I know first-hand that d-limonene poses a health risk to those exposed. In November 1998 I was poisoned by d-Limonene when it was used as a pesticide to kill termites in my home
. As a result , I now have Reactive Airway Disease and Multiple Chemical Sensitivity. The product used was promoted as "Orange Oil" and "safe , " and "natural." The label listed the ingredient as "99% d-limonene ." When applied it oxidized and became an even more potent toxin. I have lived with the health consequences of d-limonene exposure for 16 years , and throughout the years I have continued to learn about this terpene. It is toxic and it is dangerous. The MSDS for the product does not address the health consequences of inhaling d-limonene ; it states "non known
. "

Page I of3It is " unknO'v\11 11 becau e there have be ery fe"' studies , and ery few records kept on illne ss cau cd by d- Limonen e. If it hadn't been for the thorough response from indi viduals in the EPA at the tim e o r 

### my expo s ure . I \\'Ould not have been able to find out about thi chemical. I was lucky to ha c made contact "' ith someone who had worked on the regi stration of d-Limonene , and ' ho was co nc erned abo ut it appro val. Sub equently , others in the EP I\ regional office expressed co 111.:l.!rn and ass isted me in finding an s wer . Research about the health effects and toxic exp o ure r eac ti o ns to d-lim o nenc has been documented by several res pected researchers. including Dr
.Willi am W
. aza roff. niversity of California. Berkeley. "Indoor Air Chemistry , Cleanin g /\ ge nt s. Ozo ne and Toxic /\ir Contaminants , I ·inal Report : Contract No. 01-336. prepared for th e C aliforni a /\ir Re so urce s Board and the California En ironmcntal Protection Agency. CA R

eso urces Board Res earch Division ; Dr
. Anne tcincmann. Uni ersity of Washington , Dept. of Ci vil and Environmental Engineering , Environmental Impact /\ s scssment Review , Fragranced con s umer product s: Chemical emitted. ingredients unli sted. and others
. D-limonene , used in co ns um er product , e ven at lower potency than the full-strength pesticide , eau es serious health iss ue·. rurthcr comments about the health issues caused by d-Limonene when used as a pe sticide can be found in the book , Canary in the Courtroom. Ilow Pesticide Poisoning Changed a W o man 's l.i fc and ! · arced Her into Civil Action
. Please consider the serious health risks of dLimonene when making your deci ions about its use . EP A Res ponse : The Office of Pesticide Program s (OPP ) u ·e information from a variety of so urce s to bt:ttcr unders tand whether registered pc ticidc arc cau ing unanticipated adverse effect on hum an he alth
. The Agenc y collects incident data primaril through Section 6 a)( 2) o f the l· edcral In ecticidc. rungicide , and Rodenticide Act ( FIFRA) ' hich mandates registrants to submit in fo nnati o n about ad crse outcomes resulting from exposure to a pesticide for which the y ho ld a rc gis trati n . In addition. OPP may be made a' arc of incidents from other sources , such as direct reports to the Agency or reports to the National Pesticide Information Center (NPIC )
. and th es e data arc also maintained by OPP
. When evaluating human incident data , the Agency consult the OPP Incident Data System ( IDS ) and the Centers for Di sease Control and Prevention /National Institute for Occupational Safet y and I lcalth (C DC IOSH) Sentinel Event Notification ystem for Occupation Risk Pesticide s ( .'EN OR) databases for pesticide incident data on the active ingredient. Additionally, the /\gcnc y loo ks to include findings for particular pe s ticides from the Agricultural Health Stud y (/\I I )
. which i a high quality prospecti e epidemiology study evaluating the link between pc tieide u c and various health outcomes including cancer. Limonene , however , is not included in the /\I I
. De s pite it s exten s ive u c in a \vide range of product , there have been ver. few human incid ent rep ort s for limonene . re iew of human incidents " a conducted in 20 I0 ( . Winfield : 20- M/\ Y- 2010 ; 037449 3). Due to the low frequency and severit of the cases further in estigati o n wa not " arranted at that time. On! one ca e repo11ed r pirator ymptoms (ranked as low

e crit ). A part of thi response an infom1al re i w of the incident data since 20 I0 ha be en co nducted and th e results are consistent with the pre ious 20 I0 re ie\ ' ith ery few hum an incident r ep rts . Of the 19 incidents reported in the ID database only 3 ' ere associated with respiratory effect s. Only minor severity incidents were reported in the Aggregate IDS databa e for th sa me time period
. Although this database does not distinguish between types of

Page 2 of 3sy mptoms , minor incidents t pically includes skin eye or respiratory sy mptoms that resolv e rapidly
. In SENSOR , there were 17 cases reported and only 3 cases were associated with respiratory effects (ranked as low severity). The Agency will continue to monitor the incid e nt information and if a concern is triggered. additional analyses will be performed.

Page 3 of3