Page 2 of 13 EXECUTIVE SUMMARY

Polybutene is a non-drying, sticky and semi-liquid pol ymer material registered for repelling birds from roosting inside and outside of buildings. It is also used fo r repelling beavers from attacking
trees and shrubs. When birds and beavers co ntact the treated surf aces, they dislike the unpleasant sticky sensation and usually do not re turn. A Reregistrati on Eligibility Decision (RED) and a Fact Sheet on polybutene are av ailable for further reference (EPA, 1995).

There are no registered food uses for polybutene. However, there is an exemption from the requirement of a tolerance when polybutene is inco rporated in the packag ing of insect control products used on food crops. It is also appr oved as a component in adhesives, paper and laminates intended for packaging food material s. Polybutene is a common ingredient in cosmetic products (including lipstick, sunscreen a nd eye makeup at concentrations up to 50%). The Cosmetics Industry Review (CIR) Expert Pane l, an industry-appointed panel of scientists assigned to review the safety of cosmetic pr oduct ingredients, concl uded that polybutene is “relatively harmless” and safe for use in cosmetics.

The oral toxicity of polybutene is low. No treatment-related effects have been observed in laboratory animals following oral exposure to pol ybutene at doses that achieve or exceed the limit dose. The polymeric nature of the compou nd is expected to limit dermal toxicity, although dermal studies are not available. Genotoxicity st udies are negative. Inha lation toxicity has been
observed in the rat after a two-w eek exposure, but due to low volat ility, there are no concerns for inhalation exposure from current uses.

No additional toxicology data are required to su pport the registration review of polybutene. The available toxicology data, which include studie s submitted to the Agency and published studies, are considered adequate to assess the exposur e from existing uses of polybutene. A dietary exposure assessment is not needed for polybutene because of the lack of food uses.

There is a potential for residen tial handler exposure to polybute ne via the dermal route which should be evaluated during registration review. Postappli cation residential exposure and risk from dermal, inhalation, and oral (children’s’ hand-to-mouth) exposures are not of concern because no contact is expected with treated surfaces and due to the non-volatile properties of gel and liquid formulations.

During registration review, a dermal exposure assessment for occupational handlers who apply gel and liquid formulations of polybutene shou ld be conducted. No inhalation exposure assessment is required since polybut ene is a non-volatile chemical. In addition, a postapplication worker exposure assessment is not required sinc e contact is not expected from the application methods and application sites wher e polybutene resins are registered.Page 3 of 13 INTRODUCTION

The Health Effects Division's (HED's) Polybutene Registration Review Team has evaluated the information available for preparing this summary. No new polybutene data have been submitted since an assessment was completed in 1997, the prim ary source for determining the status of the polybutene database for the 1995 RED. Screening-le vel searches of Google Scholar and Science
Direct indicate that there is no new information that would impact the human health risk

assessment.

The registered product formulati ons containing polybutene are lis ted in Table 1. There is no registration on a technical product and the four active registrati ons are end-use product (EP) formulations. In addition, there are two produc ts listed under "registrat ion pending." Three of the four EPs are formulated as gels and packaged in ready-to-use tubes and the fourth is a liquid.

Table 1. Registered Products of Polybutene.

EPA Reg. No. AI % Formulation Type Product's Name

1621-17 97.0 Gel Tangle foot Bird Repellent

8254-3 49.0 Liquid 4 The Birds, Transparent Bird Repellent Liquid

8254-5 93.0 Gel 4 The Birds, Bird Repellent

55943-1 93.5 Gel Hot Foot Bird Repellent

70487-R 1 60.8 NA Pigeon Free

70487-E 1 62.8 NA K70

1. Registration pending.

USE PATTERN CHARACTERIZATION

Polybutene formulations are registered to repel pigeons, starlings and sparrows from inside and
outside of homes and structures and beavers from trees and shrubs. The use pattern for registered products is summarized in Table 2.

Table 2. Use Pattern of End-use Pr oduct Formulations of Polybutene.
EPA Reg. No.

And Name. Appl. Sites Appl. Equipment
and rate Comments

1. 1624-17, (97% ai) Bird Repellent

2. 8254-5, (93% ai), 4 The Birds Bird Repellent

3. 55946-1, (93.5% ai) Hot foot Bird Repellent Outdoor: on buildings and other
exterior structures Caulking gun or a putty knife @ 1 oz product per
linear ft. To reduce exposure to bird related diseases, wearing water proof gloves and a respirator (approved for dust) is recommended for cleaning the areas before

treatment.

4. 8254-3 (49% ai) 4 The Birds Transparent Bird Repellent Interior: of buildings
Exterior: trees and
shrubs Spray to the point of run off using a low-pressure spray gun or use a paint brush to
treat surfaces that are difficult to spray. Do not dilute before spraying. Do not apply to exterior of buildings and structures. Do not apply using aerial equipment.Page 4 of 13 The treated sites include window s ills, cornices, roof lines, gutter edges, signs, ledges, bridges, overpasses, beams, girders, struts, and supports wh ere birds can sit and roos t. Exterior sites are trees, bushes and vines adjacent to buildings and structures.

The gel formulations are applied in bands, two in ches apart for the length of the area in broken strips, leaving a one inch gap betw een beads to allow drainage of water. A putty knife can also be used to apply the gel. The recommended ap plication rate is approx imately 1 oz. of product per linear foot. Repeat applica tions may be made if the applied gel is flattened with time or
covered with dirt and debris due to heavy bird traffic.

The liquid product is either sprayed with a low pressure handgun or applied using a paint brush
to the surface of beams and ra fters (indoors) or around the trunks of trees and bushes (outdoors). In outdoor areas, repeat applicatio ns may be made at 2-3 week in tervals when the applied area has a weathered appearance. For indoor areas, no repeat applications have been recommended.

HAZARD CHARACTERIZATION

Information Available on Polybutene Toxicity : The toxicity of polybut ene was reviewed for the RED document (December, 1994). All toxicolo gy studies, except for acute toxicity and genotoxicity, were waived in that assessment, ba sed on lack of effects observed in the available studies and the expectation of mi nimal exposure from registered uses (see Tables A.1 and A.2 for profile of the studies reviewed by the Agency ). No toxicity endpoints have been identified for polybutene.

Acceptable acute toxicity studies ar e available. Polybutene is of low acute toxicity by the oral and dermal exposure routes (Category IV and III, respectively). An acute inhalation toxicity study was waived based on the viscosity of the te st material (although toxicity was noted in a two-week inhalation study which is described below). It is not a de rmal irritant (Category IV) or sensitizer, but is irritating to the eye (Category II).

Polybutene did not show evid ence of genotoxicity in the Salmonella typhimurium reverse gene mutation, Chinese Hamster Ovary (CHO) ce ll mammalian forward gene mutation and in vivo mouse bone marrow micronucleus assays. Test material purity information on the bacterial reverse gene mutation assay was required at the time of review to upgrade it to "acceptable". However, based on the lack of concern for genotoxici ty, this information is not required at this
time.

Additional toxicity data were reviewed (as brief summaries) s ubsequent to the RED, for a proposed amended tolerance exemption as an inert ingredient. In a 90-day dietary study in the rat, no toxicity (body weight changes, hematol ogical and limited clinical chemistry parameters, organ weights and histopathology) was noted at 2500 mg/kg/day in male or female rats. A published two-week inhalation toxicity study in ma le rats exposed 7 hr/day, 5 days per week showed no toxicity at doses of 70 mg/m 3 but at 700 mg/m 3 , 3 of 4 rats died from pulmonary edema and hyperemia.Page 5 of 13 Rat reproductive toxicity and ch ronic oral studies in the ra t and dog were not considered acceptable by the Agency because the integrity of the data was not validated. A published study evaluating developmental toxicity reported that no effects were observed after six months’ administration of polybutene at 1% or 10% in the diet (1968) but details were not available for review. No dermal absorption or toxicity da ta are available, but as a polymeric compound, absorption is expected to be low.

There are no registered food uses for polybutene. However, there is an exemption allowed from the requirement of a tolerance as an inert ingredient in the packaging of pheromone products used for insect control on food crops.

Polybutene is approved for food additive use when used in packaging that may come in contact with food (177.1430 of the Food Additive Regula tion of the Food and Drug Administration [FDA]). It is also an ingredient in many co smetics (including lipsticks, eye makeup and sun block), as an emulsifier or to add viscosity, at concentrations ranging from 1 to 50%. Reports on the toxicity of polybutene are av ailable in the published literatu re. The Cosmetic Ingredient Review (CIR) Expert Panel conducted a safety assessment in 1982 (reaffirmed again in 2002). CIR is an industry trade organization that spons ors review of cosmetic ingredient safety by panels of expert scien tists. The Expert Panel evaluated the available toxicological data on polybutene, including the inhalati on, subchronic oral and developm ental toxicity studies noted above, as well as numerous acute and irritation studi es in test animals as well as tests in humans on cosmetics containing polybutene.

The CIR Expert Panel included the unvalidated rat reproductive toxicity and rat and dog chronic oral studies in its review, all of which tested Po lybutene H as a 75% concen trate. In a two year oral study in the rat, no significan t toxicity or increased tumor incidence was observed at doses that tested up to 20,000 ppm polybutene in the diet . Beagle dogs administered doses up to 1000 mg/kg/day for two years also showed no adverse effects. No reproductive toxicity was observed in rats tested up to 20,000 ppm in the diet. Th e panel concluded that polybutenes do not show significant toxicity and characteri zed it as “relatively harmless” and safe for use in cosmetics products such as lipstick, eye makeup and sunscreen.

HED's Assessment of Polybutene Toxicity : HED concludes that t oxicological concern for exposure to polybutene from current pesticide use patterns is low, based on several considerations. First, the available toxicology da ta indicate low toxicity and no evidence of carcinogenicity following administration for up to two years up at high doses. There is no evidence of developmental or reproductive effect s or genotoxicity. Absorption via the dermal and oral routes is likely to be relatively low due to its polymeric structure. Second, polybutene is approved component in food packaging and is wide ly used as an ingredient in cosmetics, including lipstick, eye makeup and s un block, at concentrations as high as 50%. Third, there are no food uses and exposure from its use as a pest control agent is limite d. The volatility of polybutene is low and inhalation exposure is th erefore not of concern during application and postapplication. Therefore, at th is time there are no additional toxicology data requirements to support registration review.Page 6 of 13 Conclusions for Hazard Identificati on/Toxicology

No additional toxicology data are anticipated to support registration review of polybutene. The available toxicology data should be reviewed based on current guidelines to identify dermal endpoints, as appropriate, for assessment of handler/applicator exposure.

Although no new toxicology data are required fo r existing uses, additional studies may be required if food uses or new nonfoo d uses are proposed that would re sult in increased exposure.

DIETARY EXPOSURE

Polybutene is not registered for any agricultu ral uses or other uses that may expose food materials to polybutene residues. Therefore, a dietary exposure analysis was not conducted. However, currently there is an exemption from the requirement of a tolerance (§180.1037) for residues of polybutene in or on the raw agricultural commodities of (i) cotton seed when used as a sticker agent for formulations of the attractant gossyplure to disrupt th e mating of the pink boll worm and (ii) artichokes when used as a stic ker agent in multi-layere d laminated controlledrelease dispensers of (Z)-11-hexadecenal to di srupt the mating of the artichoke plume moth.

There may be some oral exposure to polybutene thr ough ingestion of cosmetics, such as lipstick; however, such exposure has been considered by the Cosmetics Industry Review Expert Panel when they evaluated polybutene for use in cosme tics. Therefore, no a dditional assessment of oral exposure will be undertaken by EPA during registration review.

Conclusions for Dietary Exposure

There are no agricultura l or postharvest uses that may expose food to polybutene residues. Therefore, a dietary exposure analysis was not conducted and there are no uses that would result in the need for a dietary asse ssment during registration review.

RESIDENTIAL EXPOSURE

Even though both gel and liquid formulations of polybutene are labeled for use by commercial and professional applicators, the current labels do not restrict home owners from buying and using them to get rid of birds in homes and othe r structures. Therefore, exposure to residential
handlers is to be assessed during registration review.

Adults and children occupying homes that are treated by homeowners and professional applicators result in postapplication dermal and inhalation exposure to polybutene. The postapplication dermal exposure from gel and liquid formulations is expected to be negligible
because of the lack of contact with the treate d surfaces, both inside and outside of homes. Inhalation exposure to occupants of indoor areas treated with the liquid product is not of concern
because it is a water-based formulation. There is no likelihood of children's postapplication oral exposure from indoor uses as the treated areas are not accessible and flakes do not form and fall to the ground making them ava ilable for ingestion by children.Page 7 of 13 Conclusions for Residential Exposure

Residential handler exposure assessment is required during registration review because homeowners are potentially expos ed via the dermal route when they apply gel and liquid formulations of polybutene inside and outside of homes. No postapplic ation dermal, inhalation or incidental oral exposure assessments are requ ired for indoor and outdoor uses of polybutene.

OCCUPATIONAL EXPOSURE

Occupational Exposure Characterization : Polybutene products are used by professional applicators for controllin g birds and rodents inside/outside of homes and other structures. Based on the formulation types and use pattern, the following potential expos ure scenarios were identified that are applicable to mixers, load ers, and applicators of polybutene formulations (Table 3).

Table 3. Occupational Exposure Scenarios of polybutene

EPA Reg. No. Ser. No. Handler 1 Potential scenarios Exposure Potential 2

1 Mixing/loading None expected as the product is applied "as is"

2 Applying the gel using a caulking gun to outdoor buildings and structures Dermal exposure is expected 1621-17
8254-5
55943-1 (Gels) 3 M/L/A

Applying the gel using a putty knife to outdoor buildings and structures Dermal exposure is expected

4 Transferring the liquid product into a low

pressure pump sprayer Dermal exposure is expected

5 Applying the liquid using a low-pressure sprayer to indoor and outdoor buildings, tress, and vines Dermal exposure is expected 8245-3 (Liquid)

6 M/L/A

Applying the liquid using a paint brush to indoor and outdoor buildings and trees Dermal exposure is expected

1. Since the areas treated are small, one person may wo rk as mixer, loader, and ap plicator (M/L/A).

2. Inhalation exposure is not of concern because the registered formulations are either gels or water-based liquids.

Occupational Exposure to Handlers : When polybutene products were registered, no occupational exposure assessments were conducted. At that time, it was determined that there was a low potential for exposure to handlers if these products are used as directed.

There is a potential for dermal exposure to applicat ors of gel and liquid formulations when they
treat outdoor and indoor areas in th e scenarios identified in Table 3; therefore, dermal exposure to occupational handlers should be assessed during regist ration review. Inhalation exposure is not of concern for polybutene because: (i) the active ingredient is not a volatile substance, (ii) the gel formulations are solids without any vapor gene rating properties; and (iii ) the inert ingredients in the liquid formula tion are non-volatile.Page 8 of 13 Occupational Postapplication Exposure: Given the use pattern of polybutene, no postapplication activities ar e expected to be performed in tr eated interior or exterior areas. Therefore, a postapplication exposure assessment is not anticipated during registration review.

The toxicity studies on end-use prod ucts indicate that they have m oderate acute toxicity and were assigned Signal Words such as CAUTION to WARNING. No persona l protective equipment (PPE) is required on the labels for these products because polybutene formulations are used at sites exempted from the requirement for Work er Protection Standard (WPS) language on the
label.

Conclusions for Occupational Exposure

During registration review, a new dermal expos ure assessment is required for occupational handlers of gel and liquid formul ations treating the interior a nd exterior of buildings, outdoor
areas such as tree trunks. Post application contact with treate d areas is not expected in conjunction with polybutene uses, an d therefore an occupational postapplication assessment is not required during registration review.

PUBLIC HEALTH AND PESTICIDE EPIDEMIOLOGY DATA

HED’s Toxicology and Epidemiology Branch pr ovided an incident re port for polybutene (D372034, S. Winfield, February 25, 2010). The OPP Incident Data System (IDS), the Center
for Disease Control and Prevention/National In stitute for Occupational Safety and Health (CDC/NIOSH) Sentinel Event No tification System for Occupati onal Risk (SENSOR) and the Agricultural Health Study (AHS) database were consulted for poisoning incidents on the active ingredient, polybutene. For IDS, no poisoning incidents were reporte d from 2002 to the present. Similarly, for NIOSH SENSOR, no cases were iden tified that involve po lybutene resins from 1998-2005 and no polybutene resin incidents were repor ted in the AHS. None of the databases reported any incident cases. The Agency will co ntinue to monitor the incident information on polybutene and if a concern is triggered, additio nal analysis will be in cluded in the risk

assessment.

Conclusions for Public Health and Pesticide Epidemiology Data

There were no incidents reported for polybutene and no further inves tigation is warranted at this time. However, the Agency will continue to mo nitor incident information and if a concern is triggered, appropriate action will be taken to address such incidents during registration review.

TOLERANCE ASSESSMENT AND INTERNATIONAL HARMONIZATION

There are no internati onal harmonization issues associated with polybutene due to the lack of
food uses.Page 9 of 13 ENVIRONMENTAL JUSTICE

There appear to be no particular socioeconomic subgroups that may experience a higher degree of exposure to polybutene. Pote ntial areas of environmental ju stice concerns, to the extent possible, will be considered in future huma n health risk assessments for polybutene, in accordance with U.S. Executive Order 12898, "Fed eral Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," http://www.epa.gov/compliance/resources/polic ies/ej/exec_order_12898.pdf. The Office of Pesticide Programs (OPP) typically considers the highest potential exposures from the legal use of a pesticide when conducting human health ri sk assessments, including, but not limited to, people who obtain drinking water fro m sources near agricultural ar eas, the variability of diets within the U.S., and people who may be exposed when harvesting crops. Should these highest exposures indicate potential risks of concern, OPP further refine s the risk assessments to ensure
that the risk estimates are based on the best available information.

HUMAN STUDIES

The occupational assessments anticipated durin g registration review may use exposure data from the Pesticide Handlers Exposure Database (PHED). The PHED has been reviewed from an ethics perspective and no issues were f ound that would preclude its use in the risk assessment process. No other human studies have been used to assess polybutene.Page 10 of 13 ATTACHMENTS

A. Summary of acute, subchroni c/chronic toxicity profile and endpoints and doses available on polybutene:

Table A1. Acute Toxicity Profile - Polybutene Technical.

Guideline No. Study Type MRID(s) Results Toxicity Category

870.1100 Acute oral-rat 41772401 LD 50 >5.0 g/kg IV

870.1200 Acute dermal-rabbit 41772402 LD 50 >2.0 g/kg III

870.1300 Acute inhalation-rat 1 -- -- N/A 1

870.2400 Acute eye irritation-rabbit 41772403 Eye irritant II

870.2500 Acute dermal irritation-rabbit 41772404 Not a dermal
irritant IV

870.2600 Skin sensitization-guinea pig 41772405 Not a sensitizer N/A

1. The acute inhalation study was waived based on viscosity of test material.Page 11 of 13 Table A.2. Subchronic, Chronic and Other Toxicity Profile for Polybutene.

Guideline
No. Study Type MRID No. (year)/
Classification /Doses Results

870.3100 90-Day oral toxicity (diet)

- rat 00117945 (1982) Acceptable/non-guideline 2500 mg/kg/day, administered
in diet NOAEL = 2500 mg/kg/day LOAEL = not determined (>2500 mg/kg/day)

870.3150 90-Day oral toxicity - dog Not available.

870.3200 21-Day dermal toxicity Not available.

Nonguideline -
inhalation 2-week inhalation toxicity -

rat Published article, Skyberg et al. (1990) Env. Res. 53:48-61.
Acceptability not determined
Whole-body aerosol inhalation exposure of male rats for two weeks at 70 or 700 mg/m 3 NOAEL = 70 mg/m 3

LOAEL = 700 mg/m 3 , based on pulmonary edema and hyperemia, and mortality.

870.3700a Prenatal developmental-rat Not available.

870.3700b Prenatal developmental -
rabbit Not available.

870.3800 Reproduction and fertility
effects-rat Not available.

870.4100a Chronic toxicity-rodent Not available.

870.4100b Chronic toxicity-dog Not available.

870.4200b Carcinogenicity (mouse) Not available.

870.4300 Combined chronic toxicity/carcinogenicity-rat Not available.

870.5100 Bacterial Reverse Gene Mutation Assay

( S. typhimurium strains TA97a, TA98, TA100, TA102 or TA1535) 43076602 (1993)
Unacceptable/guideline (upgradeable with submission of analysis confirming test material concentration)

0.08, 0.1, 0.33, 0.8, 1.0, 3.3 or 5.0 mg/plate, tested with and
without S9 activation NEGATIVE

No evidence of induced mutant colonies above background in S. typhimurium in the presence or absence of S9 activation. Tested up to limit dose (no cytotoxicity or precipitation observed).

870.5300 In Vitro Mammalian Cell Forward Mutation Assay (TK locus), Chinese hamster ovary cells strain
AS52 43076603 (1993)

Acceptable/guideline

0.001, 0.003, 0.010, 0.033, 0.10, 0.33 or 1.0 μL/mL in culture media, all tested with
and without S9 activation. NEGATIVE

There was no concentration-related
increase in induced mutant colonies over background observed in the presence or absence of S9 activation. Cytotoxicity was not observed; insolubility was observed at 0.33 and 1.0 μL/mL.Page 12 of 13 Table A.2. Subchronic, Chronic and Other Toxicity Profile for Polybutene.

Guideline
No. Study Type MRID No. (year)/
Classification /Doses Results

870.5385 In vivo bone marrow micronucleus assay, mouse 43076604 (1993)
Acceptable/guideline
1.25, 2.5 or 5 g/kg bw (intraperitoneal injection) with sacrifice at 24, 48 or 72 hr NEGATIVE

There was no evidence of a clastogenic and/or aneugenic effect up to the limit dose of 5 g/kg bw. No systemic toxicity observed.

870.7485 Metabolism and pharmacokinetics (rat) Not available.

870.6200a Acute Neurotoxicity (rat) Not available.

870.6200b Subchronic Neurotoxicity (rat) Not available.

870.7800 Immunotoxicity Not available.

REFERENCES

Bradley, M. J. Inert Ingredients: Polyvinyl ch loride, Butylbenzyl phthalate, and Polybutenes. Addition to Request of 6/24/81, August 12, 1982.

Bradley, M. J. Inert Ingredients: Polyvinyl ch loride, Butylbenzyl phthalate, and Polybutenes on
Artichokes. Additional Information to Request of 6/24/81, November 26, 1982. Cosmetic Ingredient Review (1982) Final Report on the Safety Assessment of Polybutene. J.
Am. Coll. Toxicol. 1(4):103-118.

Cosmetic Ingredient Review : Final Report on the Safety Assessment of Polybutene. J. Am. Coll.
Toxicol. 1(4):103-118, 1982.

Davis, D. S., D194367. PP# 3E4254: Polybutene: Re quest for Clearance as an Inert Ingredient under 40CFR§180.1001(c) an (e). November 24, 1993.

Jones, R. Structure Activity Team (S AT) Report for Polybutene. October 20, 1995.

Liem, D. S. D223859. Review of a Proposal on a Selection of Polybutene Grade for a Subchronic Feeding and a Developm ental Study (Inert). April, 26, 1996.

Ritter, D. Inert Ingredients for Use in an In sect Pheromone dispenser in Artichokes. EPA File Symbol: #8730-EUP-RR. October 13, 1981.

Ritter, D. Request to Broaden Exemption as an Inert Ingredient in all RACs, November 24,
1981. Schmidt, R. P., Polyvis OSH – Inert Ingredient Used in Proturf Systemic Fungicide, January 8,
1974.Page 13 of 13 US EPA. The HED Chapter of the Reregistra tion Eligibility Decisi on Document (RED) for Polybutene. Memo from M. Clock to J Ellenberger, December 7, 1994. HED Doc No. 011351.

US EPA: Reregistration Eligibili ty Decision (RED) – Polybutene. http://www.epa.gov/oppsrrd1/REDs/4076, 1994.

US EPA. Review of Toxicological Data P ackage on Polybutene in Support for a Tolerance Exemption Under 40 CFR 180.1001© and (e) (Inert). Memorandum from D. Liem to M. Waller dated April 21, 1995. DP Barcodes D194369, D214154.

US EPA. Review of a Toxicological Data Rebuttal and Additional Data on Polybutene in Support for an Amended Tolerance Exemption Under 40 CFR 180.1001(d) (Inert).
Memorandum from D. Liem to M. Waller dated November 1, 1995. DP Barcodes D216536,
D217639.

US EPA. EPA RED Facts: Polybutene, January, 1995.

Winfield, S. D372034. Polybutene Resins: Review of Human Incidents, February 25, 2010.

Woodrow, W. S. Amendments to EPA # 36638-EUP-G, PP # 9G2226, Heliothis virescens (tobacco budworm) Mating Disruptant Pheromone Used on Cotton, June 5, 1981.