UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: November 5, 2014 

SUBJECT: Chlorpropham: Amended and Updated Tier I Review of Human Incidents 

PC Code: 018301 DP Barcode: 0422116 

Decision No.: 494058 

Petition No.: NA 

Registration No.: NA 

Regulatory Action: NA 

Risk Assessment Type: NA Case No.: NA 

TXRNo.: NA CAS No.: 101-21-3 

MRIDNo.: NA 40CFR: NA 

FROM: 

THROUGH: 

TO: 

Shanna Recore, Industrial Hygienist 

Elizabeth Evans, Environmental Protection Specialist 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) fJ ',- 'tf.& ctftlJ/- ~o I/.( 

David Miller, Acting Branch Chief 1/v' · 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) 

Anwar Dunbar, Risk Assessor 

Risk Assessment Branch I 

Health Effects Division (7509P) 

and 

Marianne Mannix, Chemical Review Manager 

Risk Management & Implementation Branch 3 

Pesticide Re-evaluation Division (7508P) 

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Ver.Apr.08 
Summary and Conclusions 

Chlorpropham was previously reviewed in 2010 (S. Recore and K. Oo, 08/20/2010, D378702). It 

was concluded that "based on the low frequency and severity of incident cases, there does not 

appear to be a concern at thls time that would warrant further investigation." However, the 

SENSOR-Pesticide data presented in that memorandum was incorrect since the seven incidents 

described were for a different chemical. This incident analysis was conducted to correct and 

update the previous analysis. 

The current analysis shows no incidents in IDS and few incidents in SENSOR-Pesticides. 

Therefore, based on the low frequency and severity of incident cases reported for chlorpropham 

in both IDS and NIOSH SENSOR-Pesticides, there does not appear to be a concern at this time 

that would warrant further investigation. The Agency will continue to monitor the incident 

information and if a concern is triggered, additional analysis will be included in the risk 

assessment. 

I. ACTION REQUESTED 

Chlorpropham was previously reviewed in 2010 (S. Recore and K. Oo, 08/20/2010, D378702). It 

was concluded that "based on the low frequency and severity of incident cases, there does not 

appear to be a concern at this time that would warrant further investigation." However, the 

SENSOR-Pesticide data presented was incorrect. An updated incident report was requested to 

correct and update the previous analysis since the seven SENSOR-Pesticide incidents described 

were for a different chemical. 

II. BACKGROUND 

Chlorpropham is a herbicide and plant growth inhibitor used to control mouseear chickweed in 

spinach and fruiting in ginkgo trees, reduce Botrytis infection in Easter lilies as well as assist in 

their floral bud removal, and inhibit sprouting in stored potatoes. Chlorpropham is not currently 

registered for residential use. 

For this evaluation, both the OPP Incident Data System (IDS) and the Centers for Disease 

Control and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) 

Sentinel Event Notification System for Occupational Risk-Pesticides (SENSOR) database were 

consulted for pesticide incident data on the active ingredient chlorpropham (PC Code 018301 ). 

The purpose of the database search is to identify potential patterns in the frequency and severity 

of the health effects attributed to chlorpropham exposure. 

In addition, we sought information from the Agricultural Health Study (AHS). The AHS is a 

high quality prospective epidemiology study evaluating the link between pesticide use and 

various health outcomes, including cancer. Chlorpropham is not included in the AHS, and 

therefore this study does not provide information for this report. 

III. RESULTS/DISCUSSION 

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a. IDS (Incident Data System) 

OPP's IDS includes reports of alleged human health incidents from various sources, including 

mandatory Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports 

from registrants, other federal and state health and environmental agencies, and individual 

consumers. Since 1992, OPP has compiled these reports in IDS. IDS contains reports from 

across the U.S. and most incidents have all relevant product information recorded. Reports 

submitted to the IDS represent anecdotal reports or allegations only, unless otherwise stated in 

the report. 

IDS records incidents in one oftwo modules: Main IDS and Aggregate IDS: 

o Main IDS contains incidents resulting in higher severity outcomes and provides 

more detail with regard to case specifics. This system stores incident data for 

death, major and moderate incidents, and it includes information about the 

location, date and nature of the incident. Main IDS incidents involving only one 

active ingredient (as opposed to pesticide products with multiple active 

ingredients) are considered to provide more certain information about the 

potential effects of exposure from the pesticide. 

o Aggregate IDS contains incidents resulting in less severe human incidents (minor, 

unknown, or no effects outcomes). These are reported by registrants only as 

counts in what are aggregate summaries. 

From January 1, 2009 to October 23, 2014, there were no incidents reported involving 

chlorpropham in either Main or Aggregate IDS database. 

b. SENSOR-Pesticides 

The SENSOR-Pesticides database covers 11 states from 1998-2010, although reporting varies 

from state to state. Cases of pesticide-related illnesses are ascertained from a variety of sources, 

including: reports from local Poison Control Centers, state Department of Labor workers' 

compensation claims when reported by physicians, reports from State Departments of 

Agriculture, and physician reports to state Departments of Health. Although both occupational 

and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on 

occupational pesticide incidents, and is of particular value in providing that information. The 

state coordinator at each of the ll respective state Departments of Health conducts case followup activities such as obtaining medical records to verify symptoms and severity. Using 

standardized protocol and case definitions derived from poison center reporting, the state 

SENSOR-Pesticide coordinator enters the incident information into the state-based system which 

is sent to NIOSH annually to be aggregated. 

A query of SENSOR-Pesticides from 1998-2010 identifies one case involving chlorpropham (PC 

Code 01830 l) which occurred in Washington State in 200 I. This case involved two active 

ingredients chlorpropham and chlorine dioxide and two pesticide products (CIPC 2 EC and OxiClor 2). This case was low in severity and the case experienced dermal symptoms. The case 

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narrative states, "A 21-year-old female potato sorter/cleaner sought medical care after 

developing a pruritic rash. She was wearing rubber gloves while sorting potatoes." 

c. Agricultural Health Study (AHS) 

The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide 

use and various health outcomes including cancer. The AHS includes private and commercial 

pesticide applicators and their spouses. If there are AHS findings relevant to a particular 

pesticide going through registration review, the Agency will ensure they are considered in the 

problem forrnulation/scoping phase of the process and, if appropriate, fully reviewed in the risk 

assessment phase of the process. The AHS includes information on use of 80 different pesticide 

active ingredients commonly used in agriculture. Chlorpropham is not included in the AHS, and 

therefore this study does not provide information for this report. 

IV. CONCLUSION 

Based on the low frequency and severity of incident cases reported for chlorpropham in both IDS 

and NIOSH SENSOR-Pesticides, there does not appear to be a concern at this time that would 

warrant further investigation. The Agency will continue to monitor the incident information and 

if a concern is triggered, additional analysis will be included in the risk assessment. 

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