### D ocket N umb ers: Ferbam EPA

- HQ

- OPP

-2015-0567 Th iram EPA-HQ-OPP-2015-0433 www 

### . regu lation s .gov



# Ferbam and Thiram Final Work Plan Registration Review Ferbam Case Numb e r 8000 Thiram Case Number 0122

March 2016

Approved b y:

# Yu-Ting~ Di re cto r P est ic ide Re-evaluation Di v ision

Date :

### INTRODUCTION T hi s is the Environmental Protection Agency's (EPA or the Agency) Final W o rk Plan (FWP) for th e r eg istration review of fe rbam and thiram. Thi s wo rk pl an addresses pub li c com m ent s rece i ved concernin g the Pre liminary Work Plan (P WP ), which was po s te d in th e ferbam (E PA1-IQ -OPP- 2015-0567) a nd thiram registration rev iew dockets (E PA-HQ-OPP-20 15-0433 )

. Ferb am and thiram are dimethyld ithi oca rb amate fu ngicides. EPA w ill assess ferbam and thir am together during r eg istratio n review, because ferbam rapidly degrades to the mo re persistent thiram. Fer bam is primar ily reg i s te red for use on grapefruits and oranges in Florida to con tro l scab disease. It is a lso used to control anthracnose disease o n man goes in F lo rid a (as a special loca l need registration). O th e r agricultural u se sites fo r fe rbam in clude: apples , citrus, cranberri es, pears, peaches , and nectarines. There are no non - agricultur al u se si tes fo r ferbam. Thiram is registere d fo r u sc on app le s, strawberries , peaches , an d nectarin es. A tole rance without US reg istration is estab li s he d for avocado , and banana/plantain u se. It is a lso registered as a seed treatment (non

- food use). Th iram is labeled for use o n no n-bearin g tree s, s hrub s, nursery s t oc k, and o rnam e nta l s as an anima l repellent to protect crops fro m dama ge by rabbits , rodents , a nd deer. Thiram i s al so r eg istered f or non- agric ultural use on go lf course turf tees a nd gree n s . The Agency i s impl e m e ntin g th e registration rev i ew pro g ram pursuan t to Sectio n 3(g) of the F

e deral Insecticide , F un g icide, and Rodenticide Act (F IFRA), and wi ll rev iew eac h registered p es ticide every 15 years to determin e wh ethe r it co ntinu es to meet the F IFRA s ta ndard for reg is tration. Changes in sc ie nce , pub li c policy , an d p esti c id e u se p r actices occ ur over tim e. T he reg is tration r eview p rog ram is intended to mak e s ur e that, as the abi li ty to assess risk evolves and as po li cies and practices c h a nge, a ll re g istered pesticides continue to meet the statutory s tandard. T he public ph ase of reg istratio n rev ie w begins when the i nitial docket is opened for each case. Informat ion on this program is provided o n the Agency's webs ite. 1 Th e FWP b eg in s w i th a ny upd ates since the PWP was iss ued. Nex t is a s umm ary of substantive co mments rec e iv ed durin g th e public comme nt pe ri od for the PWP concerning antic ip ated data need s, expec ted ri sk asse ss ments , or the estim ate d t im el in e id e ntifi e d in the PWP , and a s ummary of th e Agency 's r es pon ses to th ose comments
. T hi s section is followed by registration review planned data needs, ri sk assess ment s expecte d to be conducted , a nd the projected reg i stra tion review timelines for ferbam an d thir am. Last ly, there is a d iscussio n of next steps. 

### U PDATES SINCE THE PWP WAS IS SUE D T he PWP for ferbam a nd thiram indicated that thira m is reg i stered fo r u se on avoca do in the U
. S

. During the 60

- day public com m e nt period , th e Thir am Task Force comm e nted that the toleranc e for a v ocado is for im po rt e d avocado es only. There are no U .S. registration s fo r thiram on avoca do. Th e FWP re fl ec t s thi s correction.

1 hnp :// www2.epa.gov/ p es ti c id e -r eevalu atio n 2SUMMARY OF COMMENTS AN D AGENCY RESPONSES Durin g the 60-day public commen t period for the ferbam and thiram PWP , which opened on October 2, 2015 and closed on D ece mb e r 1 , 2015, the Agency rece ived two publ ic comments fo r ferbam, and 4 public comments fo r thiram. Public comme nt s for ferbam were submitte d from VJP Consu ltin g on beha l f ofTami n co US Inc., a registrant, a nd the Center for Biological Diversity (C BD). VJP Cons ul tin g noted that Tam in co did not r eceive a data call-in (DCI) for ferbam for crop field trials in apples, but Tam inc o plans to bridge to app le tria l s con ducted with both thiram a nd z ira m supporte d b y comparative peach tria l s with fe rb a m , zi ram , and thiram. CB D co mm e n ted on E P A's duty to complete threatened and endan gered ( li s ted) species assessment a nd consult with the U
. S

. Fish and Wildli fe Serv ic e (F W S), and th e National Marine F i s h e ri es Serv ice (NMFS) (together, the Serv ices) , o n ferbam. Pub l ic comm e nt s for thiram were submitted from the Thiram Task Force , th e F I FRA Endangered Species Task Force (FESTF), the Physicians Committee for R espo n si b le Medicine (PCRM), and fro m CBD

. T h e co mm e nt s from the Thiram Task Fo rc e a ddr essed d ata requ ire m e nt s, and the import tole ra n ce for avocado. The comment f r om FESTF identifi ed MacDermid Agricultural So lutio n s as a FESTF member , which is entitled to rely on FESTF data for endange red species risk assessmen t s . PCRM recommends using the OEC D Test Guide lin e 223 (TG223) instead of E PA Guide lin e 850.2100 for the acute avian oral sequent ia l d ose study, in the interest o f re du ci n g th e numbers of an imal s tested

. C BD 's comments focused on E PA 's duty to consult with the Services on the registration review of thira m in accordance with the Endange red Species Act (ESA). None of th e co mments addressed the time lin e described in th e PWP, o r the plann ed ecolog i cal and human health risk assessments. In the PWP , EPA a lso sol ic ited comme nts on the spec ifi c topics of environmenta l justice , water q u a l ity co n ce rn s, and trade irritants, but no comme nt s or in fo rm atio n we re received on those i ssues. Thi s se cti o n su mmari zes the s ubmitted public comments , and provides the Age nc y ' s response. Public comments in the ir e ntirety are located in the dockets EPA- HQ-OPP- 2 015-0567 (ferbam) and EPA

- HQ-OPP-20 15-0433 (t hi ram)

. For a more d e t a i le d res p o n se, plea se ref er to the docum e nt s tit led 

### Thiram: Res ponse to Comments on th e EFED Problem Formulation for R eg i stration Rev iew and 

### Thiram: Response to Co mm ent s on th e Human H ea lth Ris k Scoping Document in Support of R eg is tration Review, wh i ch are a l so loca ted in th e thiram docket. Fe rb a m Com m e nts: Com m e nts s u b mitte d by VJP Co n s ulting, In c in EPA- H Q-O PP-2 01 5- 05 67- 000 9. 

### 1. Com m en t : VJP Consulting, on behalf ofTaminco US In c., stated that they intend to fully par t icipate in th e reg istration review process. They also noted that they we re not in receipt of a DC! forferbam requiring crop field trials in apples , but plan to bridge to existing peach data for z ir am and thiram. R esponse: E P A i s pleased that Taminco inte nd s to fully particip ate in the registration revie w process. E P A issued a ge neric data call-in (G D C I ) in s upp o r t of the r e r

eg i stration of f erbam in M ay 2008 (GDC I-0 34 801

- 26275). Taminc o was li ste d as a reg i stra nt, and guideline 860.1500-crop field trials (apple) was listed as a data requirement in this DCI. Crop field
3

### trial s fo r app le were a lso noted as require me nts in past GDC T s iss ue d in 199 3 (G DCI-034801- 17316) and in 1 991 (GDC I-0 34801-1687 3)

. S ince th is requ irement was n oted in past DCi s, EPA will not require crop field trials in apples as part of the registration review GDCI. T aminco 's plan to bridge to existing peach field trial data for ziram and thiram to fulfill thi s requirement is acceptable to EPA. Taminco should cite / submit the existing peach field trial data as soon as possibl e. 

### Thiram Comments: Comments s ubmitted by th e Thiram Ta s k Fo rce in EPA-HQ-OPP-2015-0433-0012. I. Comment: 

### The Thiram Task Force recog nizes the need for many of the s tudi es listed as ant icipated data needs for the Th iram R egis tr ation R ev iew; however , th er e are a few stud i es that th e Thiram Task Forc e would like th e Agency to reconsider

. A tw ftransferable residue (ITR) s tudy is not need ed. R esponse: At the registrant ' s request , E PA has reconsidered the requirem e nt for the ITR study , and has confirmed Lhat the data are n ecessa ry. In accordance with the updated (2007) Part 158 data requirements of the 40 CFR, TTR data are re quired for all turf use s that cou l d result in post
- application exposure to treated turf. The guidance for waiving these data was developed considering the conservative nature of the standard/default residue transfer values. The waiver criterion , requiring that MO Es are 1 0 times greater than the level of concern (LOC), was based on the data used to develop these standard / default residue transfer values

. In the case of thi ram , the LOC is 1 00; therefore, all MOEs would need to be I ,000 or above in order for th e TTR data waiver to be gra nte d. The assessment ofthir am's turf u se (go lf course) yields an MOE of 850 for children 6 to < 11 years o ld , which does not meet the criterion ; therefore, the waiver may not be granted. 2. Comment: 

### The Thiram Task Force believes that the Agency should reconsid er the need for the pollinator studies identified in the PWP. The EPA categ orizes pesticid es as " toxic to bees" 

### if th e acute contact 

### LD5o is < 1 1 11 gl bee. Ava ilable data indicate that th e con tact 

### LD 5o for ihiram is 73.72 JLg l b ee and was conside r ed by th e Agency to be practically nontoxic to bees

. Additionally, it is not believed th at th e re have be en any adve rse incid e nts involving !hiram and bees

. Respon se: A lthough thiram is categorized as practically non-toxic to adult honey bees via acute contact exposure, th ere i s considerabl e uncertainty regard in g t h e potential effects of th e compound on honey bee larval development and surviva l, as we ll as potential for chronic effects. Additional data on pollinators are needed to fu ll y characterize the risk associated with thiram use to all developmental stages of honey bees , as se n sitiv ity may vary according to li fe

- stage (adult vs. eggs, larvae , and pupae) , length of exposure (acute vs. chronic), and route of exposure (contact vs. oral). As ind icated in EPA g uidance issued in 20 14 2
, 

### assessing risks to bees involves a battery of laboratory -b ased studies (T ier 1 )

. Dependin g on the

2 USE PA. 2014. Guidance for Assessing Pesticide Risk s to Bees. Office of Pesticide Programs United States

Envi ronmental Protection Agency , Health Canada Pest Management Regulatory Agency , Califo rnia Department of Pesticide Reg ulation. June 19 , 2014. Available at: http: //www . epa.gov/pollinator-protection / pollinator-riskassessment-guidance 

### 4outco m e of those studies, se mi-field and full-field studies (Tier II and Tier III ) involving whole b ee colo nie s may be required to refine the understanding of risk to the whole colony. An absence of reported incidents does not necessarily equate to an absence of incidents given the nature of incident reporting. Incidents that do not involve acute mortality events can be difficult to identify and are very rarel y reported. 3. Comment: 

### The members of th e Thiram Task Force hold segmented labels fo rfoliar and seed trea tm e nt uses. It would be helpful to the Task Force 

### if the FWP could designate which data requirements a refor foliar uses, for seed trea tm e nt s, and for both. Re spo nse: OCSPP 850.4150, Vegetative Vigor, is app li cable to foliar uses only. All othe r request e d eco toxicity stud ies app l y to both foliar uses and see d tr eatm e nts. 

### Comments submitted by FESTF in EPA-HQ-OPP-2015-0433-0010. 4. Com ment: 

### MacDermid Agricultural Solutions, In c. , a technical reg i s tr an t , is a FESTF member and is entitled to rely on the FESTF data. R espo n se: The Agency thanks FESTF fo r it s co mm e nt , and will consider the FESTF data during the thiram registration review. 

### Comments s ubmitted by the PCRM in EPA-HQ-OPP-2015-0433-0013. 5. Comment: 

### P C RM has identified acute avian ora/toxicity data for a passerine species via Extoxne t {htlp :l/ extoxne t. or st. edu/pips /thiram. htm). The sta ted LD5 o is 

### > 100 mg l kg in redwinged blackbirds. 

## If additional data are needed, PCRM recommends using the OECD Test Guide lin e 223 (TG223) instead of EPA Guideline 850.2 1 00 in th e interest of reducing the numbers of animals used. Response: E PA will review the red-winged blackbird study refe re nced by PCRM if it is s ubmitte d to the Agency for that purpose. However, EPA notes that a limi t dose of 100 mg/kg i s unlikely to be sufficient for risk assessment. EPA wi 

### II accept TG223 studies in place of 850.2100 s tudies under the conditions laid out in EPA ' s 20 1 1 Guidance for C la ss i fy in g Studi es Con ducted Usi ng the OECD Test Guideline 223 (TG223) (Acute Avian Oral Sequential D ose Study) (http: //www.epa.gov/ pesticide-science-and-assessing-pesticide

risks / guidance-classifying-studies

- conducted-using-oecd). 

### Comments that Address Both Fcrbam and Thiram: Comments s ubmitted by CBD in E PA-HQ-OPP-2015-0567-0008 (f e rbam docket), and in EPA -HQ-OPP-2015-0433-0011 (thiram docket). 1. Comment: 

### CBD ' s co mm ents focus on the EPA ' s duty to consult with the Services on the registration review offerbam and !hiram in accordance with the ESA. CBD ' s comments mention developing listed species risk assessments, and evaluation of effec ts on listed species, and th e ir designated c riti cal habitat.


### 5Response: EPA has reviewed the comments from CBD on the registration review docket openings fo r ferbam a nd thiram, and plans to add ress many of the concerns raised by CBD as part of the implementation plan for assessing the ri sks of pesticides to li sted species based on the rec o mm endat ions of the April 2013 Nat iona l Academy of Sciences (NAS) report. E PA will address concerns spec ifi c to ferbam and thi ram in connection with the deve lopment of the final registration review decisions for ferbam and thiram. In November 2013 , the E PA , along with the S e rvices and the USDA , released a summary of their joint In terim Approaches for assessing risks to listed species from pesticides. The Interim Approaches were developed jointly by the agencies in response to the NAS report recommendations , a nd reflect a common approach to risk assessment shared by the agencies as a way of addressing sc i ent ific di fferences between th e EPA and the Se rvic es. The NAS report outlines recommendations on specific sc ie ntific and technic al issues related to th e development of pesticide risk assessments that EPA and the Services must conduct in connection with their obligations under the ESA and FIFRA. The joint Inte rim App roaches were released prior to a stakeholder workshop held on November 15, 2013. In addition , the EPA pre s ented the joint Interim Approaches at the December 2013 Pesticide Program Dialogue Committee ( PPD C) and State-FIFRA I ssues Research and Evaluatio n Group (SF IREG ) meetings. The agencies also held stakeholder works hops in Ap ril 2014 an d October 2014, and in Apri12015, allowing add iti o nal opportuni ti es for stakeholde rs to comment on the Interim Approaches. Add iti o n a l workshops are planned to enhance stakeholder involvement. As part of a phased , iterative process for developing the Interim Approaches, the agencies will also consider publ ic comments on the interim Approac hes i n connection with the development of upcom in g registration review decisions. The deta il s of the joint Interim Approaches are contained in the white paper
" Interim Approaches for National

- Level Pesticide Endangered Species Act Assessments Based on the Recommendations of the National Academy of Sciences Ap ri I 20 1 3 Report," dated November 1 , 20 1 3

. Given that the agenc ies are continuin g to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat , the ecological problem formulations supporting the FWPs for ferbam and thiram do not describe the specific ESA analysis, including effects dete rminations for specific listed species or designated cri t ical habitat, to be conducted during registration review. 

### In the ecological problem formulation documents for ferbam and thiram, EPA described the screeni n g-leve l ri sk assessment to determine the potential effects offerbam and thiram on all tax a of non- target wildlife a nd plants , which will assume that listed species and their designated cr it ica l habitats may be present in the vicinity of the applicatio n of ferbam and thiram. This screen in g -l eve l assessment will allow EPA to focus its future evaluations on the types of species where the potential for effects exists once the sc ientific methods being developed by the agencies have been fully vetted. While the agencies continue to develop a common method for ESA analysis, the planned screening

- leve l risk assessment for the registration rev iew of ferbam and thiram will describe the leve l of ESA analysis completed for these particu lar registration review cases. Once th e agencies have fully developed and imp lemented the scientific methods necessary to complete ri s k assessments for listed species


### 6

### and their designated critical habitats, these methods will be applied to subsequent analyses for ferbam and thiram as part of completing these registration reviews. P LANNE D D ATA NEE D S Table I below summarizes the planned data needs for thiram. Since ferbam degrades to thiram in the environment , EPA intends to bridge data from thiram to assess fer bam. Therefore, there are no anticipated data needs for ferbam for registration review 

### per se. The planned data needs are based on the 

### R eg istration Review: Preliminary Problem Formulation for Environmental Fate, Ecological Risk, Endange red Species, and Human H ealth Drinking Water Exposure Assessments for Ferbam and Thiram, the 

### Ferbam Scoping Document , and the 

### Thiram

. Human Health Assessment Scoping Document in Support of Registration R ev iew. The planned data needs have not changed fr om what was i ncluded i n the PWP. Tabl e 1: Pl a nn e d D a t a Nee d s f o r th e T hir a m R eg is tr a ti o n R ev i ew

Tes t l\1 a ter,ia l
A nti cipated Data Need s 

### f or T hira m 875.2100 Turf tran sfe rable residue study TGAI 12 870.3465 28-day inhalation study TGAI 24 850.1350 Mysid chronic toxicity TGAI 12 850.1400 Estuarine/ marine fish early-life stage toxicity TGAI 12 Algal toxicity (fresh water diatom Navicula 850.4500 pel/icu!osa and marine diatom Skeletonema TGAJ 12 cos tatum 850.4550 Cyanobacteria toxic i ty TGA I 12 850.2100 Av i an acute toxicity (passer i ne species) TGA I 12 850.4100 Seedli ng emergence TGA I 12 850.4150 Vegetative Vigor TGA I 12

Non- Honey bee adult acute oral toxic i ty (Tier 1) TGA1 12 guide I ine4 Non- Ho ney bee larvae acute toxicity (Tier 1) TGAI 12 gu ideline 4 Non- Honey bee adult chronic oral toxicity (Tier I ) TGAI 12 gu i de l ine 4 No n- Hone y bee larvae chronic toxicity (Tier I ) TGAI 12 guide l ine4

3 On June 27, 2012, EPA announced certain revisions in harmonized g uidelin e se rie s 850

- Ecological Effects Tests

- includin g renumbering and other designations or changes for some guideli ne s tudies. See "Fi nal Test Guidelines ; OCSPP 850 Series; Notice of Availability " 77 FR 38282, June 27,20 12. http: // www.regulations.gov/# !documentDetail; D=E PA-HO-OPPT

-2009-0 1 54-0028 4 T ier 2 and 3 s tudi es are conditional on the outcome of the scree nin g- leve l a ssess ment for terrestrial invertebrates

based on Tier I st11dies of individual bees. 

### 7Non

guideline4Nonguideline4 850.3040 4 T a bl e 1: P l a nn ed D a ta N eed s f o r th e T hira m R eg is trati o n R evi ew

Semi-field te s ting for pollinators ( tunn e l or colony f ee ding studies (Tier 2) Field trial of re s idue s in pollen and nectar (Tier 2) TEP TEP Field testi ng for poll i nators (Tier 3) TEP Crop fie l d tria ls (apple) TEP TGA I = technical grade activ e ingredient; TEP = typical e nd-u s e product 

### RI S K ASSESSMEN T S FOR REGI STRATIO N REVIE W 24 24 24

During registration revi e w , the Agency will conduct a comprehensive ecological risk assessment , including an endangered species assessment , for a ll uses offerbam and thiram. For human health, E PA wi ll conduct revised dietary and occupat io n a l r isk assessments for ferbam

. EPA will con du c t rev i sed d ietary , res ide n tial , and occupationa l r isk assessments for t hi ram dur i ng r egistration review. If toxicological e ndpoints or points of departure are revised based on the data that are anticipated to be required for registration review , they will b e considered in the new assessments , as well as any changes to the standard operating procedure s or d e fault exposure a ss umptions. Tables 2 and 3 below summarize the planned registration review risk asse ss ments based on the combined ferbam/thiram EFE D Problem Formulation, and the ferbam and thiram HED Scoping Documents
. The pla t med assessme nt s have not changed from what was included in the PWP. Tab l e 2 : Pl a nned Ri s k As se ss m e nt s f o r th e Ferbam Re g is trati o n R ev iew T y p e o f Ri s k Assess m e nt Conduct ? No te s**lol!ical anU** **!ffi: nvirofime** **tal ;Jl'a(~**  

# -**·~··** ..,.., 

# ·- ,.!..._ Comprehensive ecological 

### y Thiram , a major transformation product of ( species to be assessed ferbam , will be assessed with ferbam. include terrestrial and aquat ic organisms), inc l uding endangered species Incidents Will check for For a discussion of report e d e cological updates incidents for ferbam , s e e pag e 21 of the Problem Formulation.

. H'um iii**ll~ alth** **:·~** '"'II)-·**-::~-: ·~~** **~~%:~' ~** **~~··\·{f.~.~ -~**  - 

## .. 

# - ..**~-** 

### -

5 It i s possible to bridge crop field trial data for apple for ferbarn , ziram , and thiram. 

### 8

### Dietary Food 

### y The RED acute and chronic dietary risk Drinking water 

### y assessments did not identify risks of concern . A new dietary risk assessment may n eed to be conducted i f th ere are changes to toxico l og ical endpoints or safety fa ctor s or changes to estimated drinking water concentrations. Occupational Handlers (mixers , loaders, 

### y The revised RED occupati onal risk assessment applicators) identified post-application risks of concern . A Post-application 

### y new occupati ona l hand l er and post
- appl i cation risk assessment may be need ed to incorporate changes to toxico l ogical po i nts of departures or changes to risk assessment po li cy. Re s idential Handlers N There are no registered residential us es of Post

- application N ferba· m , therefore , a residential exposure assessmen t is not needed for registration review. Bystander 

### y During reg istrat ion review , the agency w i ll dete rmine i f a residential bystander assessment is needed fo r ferbam

. O ther Aggregate N Eva lu ates the combined risk from d i etary and residential exposures . Since there are no residential uses for fe rbam , an aggregate risk assessment includes only d ietary exposure. Cumu lative N Ferbam has not been identified as a member of a cumu l ative group with a common mechanism oftox icity and therefore, no cumulative assessment is p l anned. Tolerances 

### y During reg i strati on review , th e Agency anticipates updating the to l erance ex pression residue level s to determ in e if furth er harmonization can be achi eved

. The agency may r eeva luate the tolerance l evels fo r fe rbam if new fie ld tr ia l data i s received. The Age ncy may also cons id e r converting the tolerances for th e dimethy l dithiocarbamates (th iram, ziram , and ferbam) and the et h ylene bisdith iocarbamates (EBDCs) to being expressed as carbon disu l fide equiva l e nts. In cidents Will check for For a discussion of reported human incidents update s for ferbam, see page 1 0 of the Scoping D ocument and the Ferbam: Tier I (Scoping) Revi ew of Human Incidents and EpidemioloJ.?Y.



### 9Tab l e 3: Pl a nned Ri s k Assessments for t h e Th i ram Reg ist r a tion Review Type of Risk Assessment Conduct? Note s**!EY co}i'jgit** **1t t:** **EUil16 1iiei\fa** **JFt~ .**  ' 

## 21i

...**'1'1"""¥;;-lJ'·~··-= .,.,.,,._.,..,....~~--,~"'**  -.,M --'>'·**..~~.,,._.,_** •• ·"- Comp re hensive eco l ogical 

### y Th iram is a major transformation product of fe rbam , (species to be assessed EPA intends to assess thiram with fe rbam. include terrestrial and aquat ic o rganisms), including endangered speci es Incid ents Will check for For a discuss ion of reported ecolog ical incid en t s for update s thiram, see page 21 of th e Problem For mul ation.**'alffia~ M:t3lth** **ii.}:;~~~·,2C.'** ,,._·. H ,ii ¥ ..._ fi 

# - "" 

# ......**~-..** Dietary Food 

### y A new dietary assessment is a nticipated for Drinking water 

### y registration review to incorporate any changes to toxicologica l PODs or uncertainty fac tors (UFs), me thodologies or updated drinking water estimates. Occupational Handl ers ( mixers , loaders , 

### y Th e Agency anticipates updating the occupational ri s k applicators) assessment during registration r eview to incorporate Pos t- app li cat io n 

### y any r ev i sed toxicological PODs, c urre nt polici es or ex po s ure assessment meth o dolo g ies . Residential ' Handlers 

### y The Agency anticipates revising the res id ential Post-applica ti on 

### y expos ur e risk assessment during registration review to incorporate the required chemical-specific TTR d ata. T he Agency will evaluate th e need for spray drift and volatilization risk assessments for thiram during registration review. Other Aggregate 

### y Evaluates the combined r isk f rom dietary and residential exposu res. A revised aggregate exposure risk assessment may be ne cessary during registration rev iew to inc orporate any p otent ia l changes to the dietary or res idential assessments. Cumu lati ve 

### N EPA has not made a common mechanism of tox ici ty finding as to th iran1 and any o th er subs tances and thi r a m does not app ear to produce a tox ic m etabo li te produced by other su b s tances.

1 0

### Tolerances 

### y During registration review, the Agency anticipates examining th e tol eranc e residue levels to determine i f further harmoni zation can be achieved

. The Agency may a lso consider conv ertin g the tolerances for the dimethyl d ithiocarbamates (thi ram, ziram, and ferbam) and the ethy len e bis-dithiocarbamates (EBDCs) to being expressed as carbon disulfide eq uival e nts
. Incid ents Will check for For a discussion of reported human incidents f or upd ates thiram , see page ll of the Seepi ng Document and the 

### Thiram: Tie r 1 R eview of Human Incid ent s and Ep id em iology. T I MELINE EPA has created th e follo w ing es timated tim e lin e for the completion of the ferban1 and thiram re gis tration review in Table 4 b elow. T he projected timeline has not ch an ged s i nce the PWP
. Table 4 : Pro j ected Ferbam and Thiram Registration Review Timeline Activities Est im ated Date Opening the Docket Open Docket and 60 -d ay Public Comment Perio d October 20 15

- Completed Close Public Co mment December 20 15

- Completed Case Development F inal Work Plan March 201 6

- Comp l eted Issue DCI 6 

### 2016

- April- June Data Submission 2018

- Apr il- Jun e 60-day Publ i c Co mm e nt Pe riod for Draft Ri s k Assessments7 

### 20 19- Oct- Dec Registration Review Decision 60

- day Public Comment Period for Proposed 2020

- July

- Sept. Reg istration Rev i ew Deci s i on Re g i strat ion Revie w Decision and Begin Po s t-D ecis ion 2021 Fo ll ow-up Total (years) 6

6 There are no data req uire me nts for ferbam; therefore , a DCI will not be issued

. However , since data w ill be

brid ged from thir am o r ziram to assess ferbam, the three registration review cases are on the sa m e projected reg istration review time lin e. 7 Th e regulations gove min g Reg ist r ation Rev iew ge ne rall y requ ire the Agency to provide a publi c comment p e ri od of at least 30 calendar days for draft r isk assessme nts; see 40 CFR Part 1 55

. 53(c)

. Fo r co nv e ntion al pesticides , th e Agency plans to prov ide a 60 cal e ndar day public comment period ge n e r a ll y fo r dr aft ri s k assess m e nts. 

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### NEXT STEPS As noted previously , the Age ncy plans to require ce rtain ec ological effects a nd human health studies for thiram thro u g h a D C I , expected to b e i ss u ed in sp rin g/s ununer 20 1 6.

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