United States Prevention, Pesticides EPA 738-R-95-025

Environmental Protection And Toxic Substances September 1995

Agency (7508W)

Reregistration

Eligibility Decision (RED)

Sodium Fluoroacetate

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF 

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

CERTIFIED MAIL

Dear Registrant:

I am pleased to announce that the Environmental Protection Agency has completed its

reregistration eligibility review and decisions on the pesticide chemical sodium fluoroacetate.

The enclosed Reregistration Eligibility Decision (RED) contains the Agency's evaluation of

the data base of this chemical, its conclusions of the potential human health and environmental

risks of the current product's use, and its decisions and conditions under which this use and

products will be eligible for reregistration. The RED includes the data and labeling

requirements for products for reregistration. It may also include requirements for additional

data (generic) on the active ingredients to confirm the risk assessments.

To assist you with a proper response, read the enclosed document entitled "Summary

of Instructions for Responding to the RED". This summary also refers to other enclosed

documents which include further instructions. You must follow all instructions and submit

complete and timely responses. The first set of required responses are due 90 days from

the date of this letter. The second set of required responses are due 8 months from the

date of this letter. Complete and timely responses will avoid the Agency taking the

enforcement action of suspension against your products.

If you have questions on the product specific data requirements or wish to meet with

the Agency, please contact the Special Review and Reregistration Division representative

Frank Rubis at (703) 308-8008. Address any questions on required generic data to the Special

Review and Reregistration Division representative Leonard Ryan at (703) 308-8067.

Sincerely yours,

Lois Rossi, Director

Special Review 

 and Reregistration Division

Enclosures
SUMMARY OF INSTRUCTIONS FOR RESPONDING TO

THE REREGISTRATION ELIGIBILITY DECISION (RED)

1. DATA CALL-IN (DCI) OR "90-DAY RESPONSE"--If generic data are required for

reregistration, a DCI letter will be enclosed describing such data. If product specific data

are required, another DCI letter will be enclosed listing such requirements. If both generic

and product specific data are required, a combined Generic and Product Specific letter will

be enclosed describing such data. Complete the two response forms provided with each DCI

letter (or four forms for the combined) by following the instructions provided. You must

submit the response forms for each product and for each DCI within 90 days of the date

of this letter (RED issuance date); otherwise, your product may be suspended.

2. TIME EXTENSIONS AND DATA WAIVER REQUESTS--No time extension requests

will be granted for the 90-day response. Time extension requests may be submitted only with

respect to actual data submissions. Requests for data waivers must be submitted as part of the

90-day response. Requests for time extensions should be submitted in the 90-day response,

but certainly no later than the 8-month response date. All data waiver and time extension

requests must be accompanied by a full justification. All waivers and time extensions must be

granted by EPA in order to go into effect.

3. APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE"--You must

submit the following items for each product within eight months of the date of this letter

(RED issuance date).

a. Application for Reregistration (EPA Form 8570-1). Use only an original

application form. Mark it "Application for Reregistration." Send your Application for

Reregistration (along with the other forms listed in b-e below) to the address listed in item 5.

b. Five copies of draft labeling which complies with the RED and current regulations

and requirements. Only make labeling changes which are required by the RED and current

regulations (40 CFR 156.10) and policies. Submit any other amendments (such as formulation

changes, or labeling changes not related to reregistration) separately. You may delete uses

which the RED says are ineligible for reregistration. For further labeling guidance, refer to

the labeling section of the EPA publication "General Information on Applying for Registration

in the U.S., Second Edition, August 1992" (available from the National Technical Information

Service, publication #PB92-221811; telephone number 703-487-4650).

c. Generic or Product Specific Data. Submit all data in a format which complies

with PR Notice 86-5, and/or submit citations of data already submitted and give the EPA

identifier (MRID) numbers. Before citing these studies, you must make sure that they meet

the Agency's acceptance criteria (attached to the DCI).

d. Two copies of the Confidential Statement of Formula (CSF) for each basic and

each alternate formulation. The labeling and CSF which you submit for each product must

comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal

concentration. You have two options for submitting a CSF: (1) accept the standard certified
limits (see 40 CFR §158.175) or (2) provide certified limits that are supported by the analysis

of five batches. If you choose the second option, you must submit or cite the data for the five

batches along with a certification statement as described in 40 CFR §158.175(e). A copy of

the CSF is enclosed; follow the instructions on its back.

e. Certification With Respect to Data Compensation Requirements. Complete and

sign EPA form 8570-31 for each product. 

4. COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE--Comments

pertaining to the content of the RED may be submitted to the address shown in the Federal

Register Notice which announces the availability of this RED.

5. WHERE TO SEND PRODUCT SPECIFIC DCI RESPONSES (90-DAY) AND

APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

Document Processing Desk (RED-SRRD-PRB)

Office of Pesticide Programs (7504C)

 EPA, 401 M St. S.W.

Washington, D.C. 20460-0001

By express:

 Document Processing Desk (RED-SRRD-PRB)

Office of Pesticide Programs (7504C) 

Room 266A, Crystal Mall 2 

1921 Jefferson Davis Hwy. 

Arlington, VA 22202

6. EPA'S REVIEWS--EPA will screen all submissions for completeness; those which are not

complete will be returned with a request for corrections. EPA will try to respond to data

waiver and time extension requests within 60 days. EPA will also try to respond to all 8-

month submissions with a final reregistration determination within 14 months after the RED

has been issued. 
ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF PESTICIDE PROGRAMS

SPECIAL REVIEW AND REREGISTRATION DIVISION

REREGISTRATION ELIGIBILITY DECISION

SODIUM FLUOROACETATE

LIST C

CASE 3073
TABLE OF CONTENTS

SODIUM FLUOROACETATE REREGISTRATION ELIGIBILITY DECISION TEAM

...................................................... i

EXECUTIVE SUMMARY ........................................ iv

I. INTRODUCTION .......................................... 1

II. CASE OVERVIEW ......................................... 2

A. Chemical Overview .................................... 2

B. Use Profile .......................................... 2

C. Estimated Usage of Pesticide .............................. 3

D. Data Requirements ..................................... 4

E. Regulatory History ..................................... 4

III. SCIENCE ASSESSMENT ..................................... 9

A. Physical Chemistry Assessment ............................. 9

B. Human Health Assessment ................................ 9

1. Toxicology Assessment .............................. 9

a. Acute Toxicity .............................. 9

b. Subchronic Toxicity .......................... 10

c. Metabolism ............................... 10

d. Reference Dose ............................. 11

2. Exposure Assessment .............................. 11

a. Dietary and Occupational/Residential Exposure ....... 11

3. Risk Characterization ............................. 11

a. Toxicological Endpoints ....................... 11

b. Occupational and Residential ................... 11

C. Environmental Assessment ............................... 11

1. Ecological Toxicity Data ........................... 11

a. Toxicity to Terrestrial Animals .................. 12

b. Toxicity to Aquatic Animals .................... 14

c. Toxicity to Plants ........................... 16

2. Environmental Fate .............................. 16

a. Environmental Fate Assessment .................. 16

b. Environmental Fate and Transport ............... 17

c. Water Resources ............................ 18

3. Exposure and Risk Characterization ................... 18

a. Ecological Exposure and Risk Characterization ....... 18

IV. RISK MANAGEMENT AND REREGISTRATION DECISION ........... 29

A. Determination of Eligibility .............................. 29
1. Eligibility Decision ............................... 30

2. Eligible and Ineligible Uses ......................... 30

B. Regulatory Position ................................... 30

1. Restricted Use Classification ......................... 30

2. Endangered Species Statement ....................... 30

V. ACTIONS REQUIRED OF REGISTRANTS ....................... 31

A. Manufacturing-Use Products ............................. 31

1. Additional Generic Data Requirements .................. 31

2. Labeling Requirements for Manufacturing-Use Products ...... 31

B. End-Use Products .................................... 31

1. Additional Product-Specific Data Requirements ............ 31

2. Labeling Requirements for End-Use Products ............. 32

C. Existing Stocks ...................................... 38

VI. APPENDICES ........................................... 39

APPENDIX A. Table of Use Patterns Subject to Reregistration ....... 40

APPENDIX B. Table of the Generic Data Requirements and Studies Used to

Make the Reregistration Decision .......................... 47

APPENDIX C. Citations Considered to be Part of the Data Base Supporting the

Reregistration of Sodium Fluoroacetate ...................... 50

APPENDIX D. Product Specific Data Call-In ................... 56

Attachment 1. Chemical Status Sheets ................... 67

Attachment 2. Product Specific Data Call-In Response Forms (Form A

inserts) Plus Instructions ........................... 68

Attachment 3. Product Specific Requirement Status and Registrant's

Response Forms (Form B inserts) and Instructions .......... 72

Attachment 4. EPA Batching of End-Use Products for Meeting Data

Requirements for Reregistration ...................... 75

Attachment 5. List of All Registrants Sent This Data Call-In (insert)

Notice ........................................ 77

Attachment 6. Cost Share, Data Compensation Forms, Confidential

Statement of Formula Form and Instructions ............. 79

APPENDIX E. List of Available Related Documents ............... 86
i

SODIUM FLUOROACETATE REREGISTRATION ELIGIBILITY DECISION TEAM

Office of Pesticide Programs:

Biological and Economic Analysis Division

Alan Halverson Economic Analysis Branch

Gabe Patrick Biological Analysis Branch

Environmental Fate and Effects Division

David Farrar Science Analysis and Coordination Staff

Richard Felthousen Ecological Effects Branch

Gail Love Environmental Fate and Groundwater Branch

Health Effects Division

Charles Frick Chemical Coordination Branch

Pat McLaughlin Toxicology Branch

Winston Dang Occupational and Residential Exposure Branch

Registration Division

Bipin Gandhi Registration Support Branch

Mark Perry Registration Support Branch

Bill Jacobs Insecticide-Rodenticide Branch

Dan Peacock Insecticide-Rodenticide Branch

Special Review and Reregistration Division

Leonard Ryan Accelerated Reregistration Branch

Kathleen Depukat Accelerated Reregistration Branch

Policy and Special Projects Staff

Jean Frane

Office of Compliance:

Mickey Post
GLOSSARY OF TERMS AND ABBREVIATIONS

ii

ADI Acceptable Daily Intake. A now defunct term for reference dose (RfD).

AE Acid Equivalent

a.i. Active Ingredient

ARC Anticipated Residue Contribution 

CAS Chemical Abstracts Service

CI Cation

CNS Central Nervous System

CSF Confidential Statement of Formula

DFR Dislodgeable Foliar Residue

DRES Dietary Risk Evaluation System

DWEL Drinking Water Equivalent Level (DWEL) The DWEL represents a medium specific (i.e. drinking

water) lifetime exposure at which adverse, non carcinogenic health effects are not anticipated to

occur.

EEC Estimated Environmental Concentration. The estimated pesticide concentration in an environment,

such as a terrestrial ecosystem.

EP End-Use Product

EPA U.S. Environmental Protection Agency

FDA Food and Drug Administration

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FFDCA Federal Food, Drug, and Cosmetic Act

FOB Functional Observation Battery

GLC Gas Liquid Chromatography

GM Geometric Mean

GRAS Generally Recognized as Safe as Designated by FDA

HA Health Advisory (HA) The HA values are used as informal guidance to municipalities and other

organizations when emergency spills or contamination situations occur.

HDT Highest Dose Tested

LC Median Lethal Concentration. A statistically derived concentration of a substance that can be 50

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.

LD50 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.

LD Lethal Dose-low. Lowest Dose at which lethality occurs lo

LEL Lowest Effect Level

LOC Level of Concern

LOD Limit of Detection 

LOEL Lowest Observed Effect Level

MATC Maximum Acceptable Toxicant Concentration

MCLG Maximum Contaminant Level Goal (MCLG) The MCLG is used by the Agency to regulate

contaminants in drinking water under the Safe Drinking Water Act.

μg/g Micrograms Per Gram

mg/L Milligrams Per Liter

MOE Margin of Exposure 

MP Manufacturing-Use Product

MPI Maximum Permissible Intake

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

N/A Not Applicable

NOEC No effect concentration

NPDES National Pollutant Discharge Elimination System
GLOSSARY OF TERMS AND ABBREVIATIONS

iii

NOEL No Observed Effect Level

NOAEL No Observed Adverse Effect Level

OP Organophosphate

OPP Office of Pesticide Programs

PADI Provisional Acceptable Daily Intake

PAG Pesticide Assessment Guideline

PAM Pesticide Analytical Method

PHED Pesticide Handler's Exposure Data 

ppb Parts Per Billion

PPE Personal Protective Equipment

ppm Parts Per Million

PRN Pesticide Registration Notice

Q The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model *

1

RBC Red Blood Cell

RED Reregistration Eligibility Decision

REI Restricted Entry Interval

RfD Reference Dose

RS Registration Standard

SLN Special Local Need (Registrations Under Section 24 (c) of FIFRA)

TC Toxic Concentration. The concentration at which a substance produces a toxic effect. 

TD Toxic Dose. The dose at which a substance produces a toxic effect.

TEP Typical End-Use Product

TGAI Technical Grade Active Ingredient

TLC Thin Layer Chromatography

TMRC Theoretical Maximum Residue Contribution

torr A unit of pressure needed to support a column of mercury 1 mm high under standard conditions.

FAO/WHO Food and Agriculture Organization/World Health Organization

WP Wettable Powder

WPS Worker Protection Standard
iv

EXECUTIVE SUMMARY

The Environmental Protection Agency has completed an assessment of the potential human

health and environmental risks associated with the pesticidal use of sodium fluoroacetate in the

United States. Based on its review of the targe database, the Agency has determined that the

currently registered uses will not cause unreasonable risk to humans or the environment and that

these uses are therefore is eligible for reregistration. 

Sodium fluoroacetate (Compound 1080) is an acute toxicant predacide against coyotes

which prey on sheep and goats. Currently registered end-use products are 1% solutions which are

injected into the rubber reservoirs of Livestock Protection Collars. These collars are strapped to

the throats of sheep or goats. Coyotes attempting to kill collared livestock are likely to puncture

the collars and to be fatally poisoned by sodium fluoroacetate as a result.

Sodium fluoroacetate is highly toxic to warm blooded animals, including humans, when

taken internally. Additionally, sodium fluoroacetate may pose a high acute risk to non-target

birds and mammals that may scavenge the carcasses of predators that are killed from biting the

collared livestock. State-limited registrations for sodium fluoroacetate collars have been issued

in Texas, New Mexico, Wyoming, Montana, and South Dakota. The use of these products are

further limited to only those states which have an EPA-approved certification and training

program, which currently includes only Texas, New Mexico, Wyoming, and Montana. The use

is further restricted within these four states to specific counties when there is potential for adverse

effects to endangered species. 

Before reregistering the products containing sodium fluoroacetate, the Agency is requiring

that product specific data, revised Confidential Statements of Formula (CSF) and revised labeling

be submitted within eight months of the issuance of this document. These data include product

chemistry for each registration. After reviewing these data and any revised labels and finding

them acceptable in accordance with Section 3(c)(5) of FIFRA, the Agency will reregister a

product. 
1

I. INTRODUCTION

In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended

to accelerate the reregistration of products with active ingredients registered prior to November

1, 1984. The amended Act provides a schedule for the reregistration process to be completed in

nine years. There are five phases to the reregistration process. The first four phases of the process

focus on identification of data requirements to support the reregistration of an active ingredient

and the generation and submission of data to fulfill the requirements. The fifth phase is a review

by the U.S. Environmental Protection Agency (referred to as "the Agency") of all data submitted

to support reregistration.

FIFRA Section 4(g)(2)(A) states that in Phase 5 "the Administrator shall determine

whether pesticides containing such active ingredient are eligible for reregistration" before calling

in data on products and either reregistering products or taking "other appropriate regulatory

action." Thus, reregistration involves a thorough review of the scientific data base underlying a

pesticide's registration. The purpose of the Agency's review is to reassess the potential hazards

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 the pesticide meets the "no

unreasonable adverse effects" criterion of FIFRA.

This document presents the Agency's decision regarding the reregistration eligibility of

the registered uses of sodium fluoroacetate. The document consists of six sections. Section I is the

introduction. Section II describes sodium fluoroacetate, its uses, data requirements and regulatory

history. Section III discusses the human health and environmental assessment based on the data

available to the Agency. Section IV presents the reregistration decision for sodium fluoroacetate.

Section V discusses the reregistration requirements for sodium fluoroacetate Finally, Section VI

is the Appendices which support this Reregistration Eligibility Decision. Additional details

concerning the Agency's review of applicable data are available on request.
2

II. CASE OVERVIEW

A. Chemical Overview

The following active ingredient is covered by this Reregistration Eligibility

Decision:

Common Name: Sodium Fluoroacetate

Chemical Name: Sodium Monofluoroacetate 

Chemical Family: Fluoroacetic Acid

CAS Registry Number: 62-74-8

OPP Chemical Code: 075003

Empirical Formula: F-CH2-C-O2-Na

Trade and Other Names: Compound 1080

Basic Manufacturer: U. S. Department of Agriculture-registrant

Tull Chemical Company, Oxford. AL.-manufacturer

B. Use Profile

Presented below is information on the currently registered uses with an overview

of use sites and application methods. A detailed table of the registered uses of sodium

fluoroacetate is in Appendix A.

For Sodium Fluoroacetate:

Type of Pesticide: Predacide

Mode of action: Stomach poison.
3

Use Sites: Sheep, lambs, kids, goats, dairy goats (lactating or

unspecified), goats (wool/angora animal)

Target Pests: Product kills coyotes preying on sheep or goats.

 

Formulation Types Formulation Intermediate - 90% a.i. 

Registered: Collar: 1% a.i. available. All Collars contain 1.1 oz

of formulated material which is equal to

approximately .00067 lbs a.i./collar.

Method and Rates of 

Application: When predation is anticipated, collars (one collar per

collared animal) are strapped in place with the

rubber toxicant reservoirs positioned in the throat

regions of sheep or goats in target flocks or herds.

The sodium fluoroacetate solution is released if a

collar reservoir is punctured by an attacking coyote

or by another agent. 

Up to 20 collars may be used in fenced pastures up

to 100 acres in size. Up to 50 collars may be used

in pastures of 101 to 640 acres. Up to 100 collars

may be used in pastures of 641 to 10,000 acres.

Use Practice Limitations: For a complete listing of product limitations, see

Section V, Labeling Requirements for End-use

Products.

C. Estimated Usage of Pesticide

This section summarizes the best estimates available for the pesticide uses of

sodium fluoroacetate. These estimates are derived from a variety of published and

proprietary sources available to the Agency. The data, reported on an aggregate and site

basis, reflect annual fluctuations in use patterns as well as the variability in using data

from various information sources. Table 1, below, summarizes the amounts of sodium

fluoroacetate used by site. 
4

Table 1. Estimates of Typical Usage of Sodium Fluoroacetate

Site Head Available Head Treated Site Treated Lbs a.i.

(000) (000) (%) applied

Sheep - US 9080- 10850 0.6 - 0.7 <0.01 <1

MT only 520 - 580 - - -

NM only 460 - 510 - - -

SD only 540 - 590 - - -

TX only 1710 - 1940 - - -

WY only 830 - 850 - - -

Goats - US 2250 - 2550 0.2 <0.01 <0.5

NM only 80-90 - - -

TX only 1650 - 1960 - - -

Total - US 11330 - 13400 0.8 - 0.9 <0.01 <1

1987 Census of Agriculture: US New Mexico Agricultural Statistics, 1988

Pesticide Use in Wyoming, 1990 South Dakota Agriculture on the Move, 1993-1994

Wyoming Agricultural Statistics, 1992 Texas Ag. Facts, Annual Summary, 2/25/94Montana

Agricultural Statistics, 1987 

USDA/APHIS Animal Damage Control

EPA information, reports and proprietary sources

Notes: Coyote is the only active pest. Goats and sheep are the only active sites. Method of application is by

collar.

D. Data Requirements

The data required to support the uses of sodium fluoroacetate are identified in

Appendix B. This includes all data requirements identified by the Agency to support

reregistration for currently registered use.

E. Regulatory History

Origins and Early Development

This chemical case pertains to a large "family" of chemicals which are metabolized

in the manner of fluoroacetic acid and which, consequently, are very toxic (Pattison,

1959). Of these chemicals, sodium monofluoroacetate (Compound 1080) and

fluoroacetamide (Compound 1081) have been registered as pesticides in the U.S. For

reasons outlined below, there no longer are any registered uses of fluoroacetamide in the

U.S. Legal use of sodium monofluoroacetate is limited to livestock protection collar

products.

Poisons in the fluoroacetic acid "family" occur naturally in Western Australian and

South African plants that have been implicated in the poisoning of livestock (Aplin, 1979;

Pattison, 1959). The gifblaar plant (Dichapetalum cymosum) of South Africa arises as
5

small tufts of leaves and flowers from long and extensively branched underground stems.

Africans have used extracts of gifblaar (which means "toxic leaf") and related plants as

arrow poisons.

The active substance in gifblaar was extracted as its potassium salt, potassium

fluoroacetate, in 1943 or 1944 (Marais, 1944 cited by Pattison, 1959). By that time,

research already had been undertaken on synthesized fluoroacetic acid and related

compounds.

Synthesis of fluoroacetic acid was reported in 1896 by the Belgian researcher

Swarts (cited by Pattison, 1959). Fluoroacetic acid was patented in Germany in 1930 as

a mothproofing agent. Subsequently, Germans researched a number of related compounds

as potential chemical warfare agents and systemic insecticides. In the mid-to-late 1930s,

Polish military researchers discovered that fluoroacetate compounds are extremely toxic

materials. Much of the research conducted in Nazi-occupied countries prior to the end of

World War II was either lost or very late in being reported publicly. The escape of a

Polish scientist to England brought elements of the knowledge gained in Poland to the

allied side.

Further research took place in England and in the U.S. English scientists

ultimately concluded that "compounds that form fluoroacetic acid by hydrolysis and/or

oxidation are toxic." (Pattison, 1959, p. 19)

In the U.S., research on compounds related to fluoroacetic acid led to several

developments, including the development of sodium fluoroacetate as a rodenticide and

mammalian predacide and fluoroacetamide as a rodenticide. The names 1080 and 1081

for sodium fluoroacetate and fluoroacetamide, respectively, came from the invoice

numbers that these materials were assigned in U.S. Government laboratories (Peacock,

1964).

Extensive research on this family of chemicals after World War II led to a general

understanding of the mode of toxic action and the development of analytical methods

which, if not extremely sensitive by present standards, were at least able to detect the use

of compounds related to fluoroacetic acid in certain homicides (Pattison, 1959). However,

the problem of poor recovery of sodium fluoroacetate in or on animal tissues remained

until the mid 1980s (Kimball and Mishelanie, 1993).

U.S. Regulatory History of Sodium Fluoroacetate

Development and use of sodium fluoroacetate as a predacide and rodenticide in the

U.S. began in the 1940s (e.g., Robinson, 1948), prior to the 1947 enactment of the

Federal Insecticide, Fungicide and Rodenticide Act (1947) by which requirements for

Federal registration of pesticide products were instituted. Products containing sodium

fluoroacetate were among those registered shortly after the registration requirement went
6

into effect. Pattison (1959) reports that the Monsanto Corporation produced about 5 tons

of sodium fluoroacetate in 1948. In 1955, Monsanto's 90% sodium fluoroacetate product

was transferred to Tull Chemical Company of Oxford, AL. By the early 1970s, Tull

Chemical Company was the only firm legally producing sodium fluoroacetate for pest

control purposes in the U.S. Tull's registered product at the time, EPA Registration No.

5217-1, was a 90% sodium fluoroacetate concentrate which was labeled for mixing baits

that could be applied to control a variety of rodents and predatory mammals.

In 1964 and again in 1971, the use of poisons to control predatory mammals were

reviewed by select committees (Leopold, et al 1964; Cain, et al, 1972). Following the

issuance of the "Cain Report", President Nixon issued Executive Order 11643, which

banned the use of poisons to control predators on Federal lands. Shortly thereafter, EPA

issued PR Notice 72-2 which canceled all registered predator control uses of sodium

fluoroacetate, sodium cyanide, and strychnine (Ruckelshaus, 1972). Subsequent to the

cancellation of predacidal uses of sodium fluoroacetate, several parties sought to have such

uses restored.

There was a period of illegal use of sodium fluoroacetate as a predacide in

Wyoming from 1975 to 1977 (Thomas, 1983, p. 22; see also Nissen, 1982, p. 79; and

Johnson, 1978).

In 1977, the U.S. Department of the Interior (USDI) applied for an Experimental

Use Permit (EUP) to investigate the potential risks and benefits associated with the use of

sodium fluoroacetate in "toxic collars" which would be placed on the necks of sheep and

goats. Rubber pouches containing sodium fluoroacetate solution would be positioned

around the animals' throat regions where they would be likely to be ruptured by the teeth

of coyotes that attempted to kill the livestock with species-typical throat bites.

In 1981, EPA was petitioned by the USDI and livestock interests to revisit the 1972

predacide cancellation decision with respect to sodium fluoroacetate. EPA responded by

holding informal hearings on the issue in 1981 and formal, Subpart D administrative

hearings in 1982. The Subpart D hearings considered reinstatement of sodium

fluoroacetate in injected-carcass bait stations and three additional types of applications:

toxic collars, small "single-dose baits" intended to provide enough toxicant to reliably kill

one coyote, and "smear posts." The initial and final decisions (Nissen, 1982; Thomas,

1983) permitted EPA to consider applications for registration of sodium fluoroacetate in

toxic collars and single-dose baits and rejected the carcass baits and smear posts.

On July 18, 1985, EPA granted a registration to USDI for a toxic collar product

(EPA Registration Number 6704-85). By then, the product was called the "Livestock

Protection Collar." In 1986, this product was transferred to the Animal and Plant Health

Inspection Service (APHIS) of the U.S. Department of Agriculture (USDA). Its new

Registration No. became 56228-22. Since 1987, five State-limited registrations have been

issued for Livestock Protection Collars. These products permit use of collars in Montana,
7

New Mexico, South Dakota, Texas, and Wyoming. However, there is no approved

training and certification program in South Dakota. A concentrate product registered to

APHIS (56228-26) that is limited to use in the manufacture of Livestock Protection Collars

and the six registered livestock collar products mentioned above are the only registered

pesticide products in the U.S. which legally contain sodium fluoroacetate.

In the mid 1980s, USDI and later APHIS obtained EUPs which authorized field

trials with sodium fluoroacetate single-dose baits made of tallow. These baits each

contained 5 mg of active ingredient. However, sodium fluoroacetate was never registered

for this use pattern.

The rodenticidal uses of sodium fluoroacetate were not directly affected by

Executive Order 11643 or by PR Notice 72-2. However, the U.S. Department of the

Interior withdrew its sodium fluoroacetate rodenticide products following the issuance of

Executive Order 11643. At the time, Tull's 5217-1 product and dozens of intrastate

registrations for rodenticidal uses of sodium fluoroacetate remained valid. In 1978, EPA

classified all legal uses of sodium fluoroacetate as "Restricted" due to "Acute oral toxicity

hazard to nontarget organisms, use and accident history." (Costle, 1978)

In the mid 1970s, EPA placed the non-predacidal uses of sodium fluoroacetate into

its RPAR ("Rebuttable Presumption Against Registration") process, the forerunner to what

now is called "Special Review." On December 1, 1976, EPA's "Position Document 1"

(PD1) was published (41FR52792, 1976). EPA announced a preliminary decision in the

RPAR in a second document, the PD 2/3, on November 4, 1983 (Barbehenn, et al, 1983).

After consideration of responses to the PD2/3, EPA issued its final decision in the form

of a PD4 document in July of 1985 (Anonymous, 1985). The PD 4 called for retention

of all rodenticidal uses of sodium fluoroacetate that were permitted at that time, but also

imposed significant requirements to modify labels and to supply missing research data.

The PD4 represented a significant change in EPA's regulatory position from that taken in

the PD 2/3 document, which had recommended cancellation or denial of many uses and

modification of all others except those for control of commensal rodents "in and around

buildings and ships" (Barbehenn, et al, 1983).

The data call-in issued with the PD4 sought information on the chemistry, residue

chemistry, environmental fate, toxicology, and ecological effects of sodium fluoroacetate.

The PD4 also dictated that 0.02% was the highest active ingredient strength that could be

used for prairie dog control, where such use was permitted, and for ground squirrel

control within the range of the California condor. EPA gave registrants whose products

were used in such areas the option of developing efficacy data "to establish the lowest

effective concentration" if the 0.02% level did not appear to be effective (Anonymous,

1985). The Agency reserved the right to modify the decisions reached in the PD4.

Tull's product 5217-1 was canceled "by operation of law on February 18, 1986"

(Yost, 1989) because the company did not respond to a November 22, 1985, "Notice of
8

Intent to Cancel" (Campt, 1985) requiring that an application for amended registration was

submitted within 90 days of the letter. Later, other parties indicated that they would

provide the data that Tull would not commit to obtain. On November 13, 1986, Tull was

granted a registration (5217-2) for a 90% sodium fluoroacetate product that could be used

only as a source of active ingredient for registered sodium fluoroacetate products. Along

with this registration, EPA issued a schedule for supplying missing data pertaining to

Tull's new product.

After two deadlines for submitting data for Tull's new product (5217-2) passed,

EPA refrained from taking immediate cancellation action. Instead, EPA met with parties

(e.g., end-use registrants, user groups) concerned with the potential loss of a source of

sodium fluoroacetate for controlling rodents. After the various meetings had concluded,

EPA issued revised data call-ins in December 1987 pertaining to 5217-2 and to the

rodenticidal uses of sodium fluoroacetate (Tinsworth, 1987a,b). Due to lack of

appropriate responses toward supplying the data required by the 1985 and 1987 data callins (Campt, 1988), EPA proceeded toward canceling Tull's manufacturing use concentrate

(5217-2). The product was canceled on February 21, 1989 (Yost, 1989). Subsequently,

all "special local needs" registrations issued under §24(c) of FIFRA were canceled, and

all pending applications for Federal registration of intrastate products containing sodium

fluoroacetate were denied. These actions were completed by August 9, 1990 (Campt,

1990).

Regulatory Status of Sodium Fluoroacetate

The currently registered uses of sodium fluoroacetate are strictly limited to

livestock protection collars as a predacide in those states which have registrations and EPA

approved certification and training programs. Since all other predacidal uses were canceled

by the Administrator in 1972, as described above in the regulatory history, additional

predacidal uses cannot be granted without observation of the procedures for reconsidering

cancellation decisions set forth in 40 CFR Part 164, Subpart D. 

Under the provisions of Subpart D, an application for a new predicidal use of

sodium fluoroacetate would require the submission by an applicant of substantial new

evidence which might have affected the cancellation decision and could not have been

made available to the Administrator during the prior proceeding. In addition, Subpart D

requires that the Administrator conduct a hearing before granting reconsideration of the

1972 cancellation decision.

U.S. Regulatory History of Fluoroacetamide

Fluoroacetamide (Compound 1081) was first registered as a pesticide in the U.S.

in 1972. In 1976, EPA began an RPAR for this compound because of potential hazards

to humans and nontarget animals. In 1978, all uses of fluoroacetamide were classified as

"Restricted" because of "acute oral toxicity" (Costle, 1978) and the absence of a true
9

antidote. In 1979, label changes were adopted to address the Agency's most critical

concerns by limiting use of the sole registered product to sewers. As a result, the RPAR

process with respect to this chemical was concluded (PD2, Feb. 28, 1980 - 45FR 13189).

Fluoroacetamide ultimately was canceled in 1989 after the registrant of the only product

failed to pay the registration maintenance fee.

III. SCIENCE ASSESSMENT

A. Physical Chemistry Assessment

Sodium fluoroacetate is a sodium salt of fluoroacetic acid which is a tan colored

alkaline powder with a pH of 10.3. This is probably due to the sodium hydroxide

impurity. It melts at 197-203 C with decomposition. It is soluble in water but practically

insoluble in all non-polar solvents. Sodium fluoroacetate is stable in sunlight, at a

temperature of 54 C, and in tin coated metal containers.

B. Human Health Assessment

1. Toxicology Assessment

The toxicological data base on sodium fluoroacetate is adequate and will

support reregistration eligibility.

a. Acute Toxicity

Table 2. Acute Mammalian Toxicity

TEST RESULTS CATEGORY

Oral LD50--rat LD 0.22 mg/kg I

50

Dermal LD50--rabbit LD 277.1 mg/kg M; II 50

 324.2 mg/kg F

Eye irritation--rabbit slight irritation III

Dermal irritation--rabbit not irritating IV

An acute oral toxicity study with rats used 90.0% sodium

fluoroacetate. The LD was 0.22 mg/kg, which is toxicity category I 50

(MRID 40016971). An acute oral toxicity study with coyotes used doses

of sodium fluoroacetate diluted with water. The LD50 was 0.12 mg/kg

sodium fluoroacetate, which is toxicity category I (MRID 00065627).

Literature reports have indicated oral LD50s of 0.10 mg/kg for rats, 0.50

mg/kg for mice, 0.066 mg/kg for dogs, and 0.34 mg/kg for rabbits. The

human oral LDlo has been reported as 0.714 mg/kg, and the potentially

toxic dose for humans has been stated as 0.5-2.0 mg/kg (Sax and Lewis,

1989).
10

An acute dermal toxicity study with rabbits used technical sodium

fluoroacetate. The LD was 277.1 mg/kg for males and 324.2 mg/kg for 50

females. The animals showed lethargy, diarrhea, and convulsions

preceding death, along with extensive hemorrhage of the thymus and

congestion of the lungs. This is toxicity category II (MRID 152129). 

A primary eye irritation study used a 1.0% aqueous solution of

sodium fluoroacetate with rabbits. There was slight irritation and slight

chemosis, which is toxicity category III (MRID 40402603). A primary

dermal irritation study also used a 1.0% aqueous solution on rabbits.

There was only transient slight edema on one rabbit and the compound was

considered not irritating (MRID 40402604).

Requirements for acute inhalation toxicity and dermal sensitization

studies were waived due to the severe acute toxicity of the compound and

the restriction of its use in a livestock protection collar.

b. Subchronic Toxicity

Technical sodium fluoroacetate was administered by gavage for 13

weeks to Crl:CD(SD)Br rats. The doses were 0, 0.05, 0.20, or 0.50

mg/kg/day. The NOEL was 0.05 mg/kg/day. The LOEL was 0.20

mg/kg/day, based on dose-related findings in histopathology

(hypospermatogenesis, fusion bodies, and immature or abnormal sperm)

and decreased size and weight of testes and epididymides in males.

Females had dose-related increases in absolute and relative heart weights

at the mid and high doses (Wolfe, 1988).

In a study with male Sprague Dawley rats, the animals were dosed

with 0, 0.07, 0.19, or 0.71 mg/kg/day of sodium fluoroacetate in their

drinking water for seven days. This was followed by 21 days without the

test compound. A group of rats from each dose level was killed each day

of treatment and on days 3, 7, 14, and 21 after dosing. The testes, kidneys

and liver were examined. Testicular atrophy and nonreversible tubular

degeneration were found at the mid and high dose. Testicular atrophy with

reversible tubular degeneration was found at the low dose. No effects on

liver or kidney were seen. The lowest dose was the LOEL (MRID

40016990).

c. Metabolism

Fluoroacetate in the mammalian body is converted to fluorocitrate.

This compound inhibits the enzyme aconitase, thus blocking the citric acid

cycle. This leads to accumulation of citric acid, which may cause
11

convulsions and death from cardiac failure or respiratory arrest (Gribble,

1973).

Sodium fluoroacetate can be absorbed through the gastrointestinal

tract, respiratory tract, or open wounds, but only slowly through intact skin

(Sax and Lewis, 1989).

d. Reference Dose

The RfD was determined to be 0.00002 mg/kg/day. This was based

on the 13-week subchronic oral rat study, in which the NOEL was 0.05

mg/kg/day. An uncertainty factor of 3000 was used to account for

interspecies extrapolation, intraspecies differences, and lack of additional

studies (Ghali, 1994).

2. Exposure Assessment

a. Dietary and Occupational/Residential Exposure

Under the current permitted use pattern there will be no sodium

fluoroacetate exposure to the general population. Based on the use

information, there are no applicator/mixer/loader or post-application

exposure concerns other than following the label restriction for use by

certified personnel only.

3. Risk Characterization

a. Toxicological Endpoints

Because of the specific nature of this registered use, the primary

concern is for the potential risk of acute toxicity.

b. Occupational and Residential

There are no uses of sodium fluoroacetate in residential

environments. Based on the use information, potential risk for acute

toxicity to workers exposed to sodium fluoroacetate is not expected.

C. Environmental Assessment

1. Ecological Toxicity Data 

The Agency has adequate data to assess the hazard of sodium fluoroacetate

to nontarget organisms.
12

a. Toxicity to Terrestrial Animals

In order to establish the acute and subacute toxicity of sodium

fluoroacetate to birds, the following tests were required using the technical

grade material: one avian single-dose oral LD study on one species; the 50

bobwhite quail (Colinus virginianus) or preferably the mallard duck (Anas

platyrhyncos); two subacute dietary LC studies on one species of 50

waterfowl (preferably the mallard duck) and one species of upland game

bird (preferably the bobwhite quail or the ring-necked pheasant (Phasianus

colchicus).

(1) Birds, Acute and Subacute

Acute oral toxicity

The acute oral LD50 value for the technical grade of sodium

fluoroacetate for avian species has been reported in the literature.

Hudson et al. (1984) reported the acute oral LD50 values for the

ring-necked pheasant, mallard duck and chukar (Alectoris graeca)

to be 6.4 (95% C.I. = 3.85-10.8), 9.1 (95% C.I. = 5.6-14.6) and

3.51 (95% C.I. = 2.58-4.78) mg/kg, respectively. Ward and

Spencer (1947) determined the acute lethal doses for numerous

avian species and reported LD50 values as low as 3.0, 5.0, and 15

mg/kg for the widgeon (Mareca americana), golden eagle (Aquila

chrysaetos), and black vulture (Cartharista urubu), respectively.

Atzert (1971) reported the LD50 for the black-billed magpie (Pica

pica) to be 1 mg/kg. In addition, the USDA conducted a series of

acute oral LD tests on the magpie to get toxicity data for a species 50

that is likely to scavenge the carcasses of coyotes and/or livestock

(Burns and Connolly, 1992). Results of these studies showed that

the acute oral LD50 for the magpie ranged from 1.78 mg/kg to 2.3

mg/kg, depending on temperature and season.

These data indicate that sodium fluoroacetate is very highly

toxic to avian species on an acute oral basis. The guideline

requirements for this test have been satisfied. Table 3, below is a

data summary for the acute toxicity of sodium fluoroacetate to avian

species.
13

Table 3.

AVIAN ACUTE ORAL TOXICITY DATA

Species LD mg/kg Conclusions 50

Mallard duck 9.1 highly toxic

Chukar 3.5 highly toxic

Ring-necked Pheasant 6.4 highly toxic

Widgeon 3.0 highly toxic

Golden eagle 5.0 highly toxic

Black vulture 15.0 highly toxic

Black-billed Magpie 1.0 - 2.3 highly toxic

Subacute dietary toxicity

Campbell et al. (1994) reported that the avian dietary LC50

values of sodium fluoroacetate for the mallard duck and bobwhite

quail were 231 (95% C.I.=150-338) and 486 (95% C.I.=339-696)

ppm, respectively (MRID #s 43210602; 43210601). Based on these

data, sodium fluoroacetate can be classified as highly toxic to avian

species on a dietary basis. The guideline requirements for a dietary

study have been satisfied. Table 4 is a data summary for the

dietary toxicity of sodium fluoroacetate to avian species.

Table 4.

AVIAN SUBACUTE DIETARY TOXICITY DATA

Species LC ppm Conclusion 50

Bobwhite quail 486 highly toxic

Mallard duck 231 highly toxic

(2) Birds, Chronic

Substantial chronic exposure to birds is not expected with

use of the sodium fluoroacetate livestock protection collar.

(3) Mammals

Wild mammal testing may be required for a pesticide

depending on the results of the lower tier studies such as acute and

subacute testing and on the intended use pattern and pertinent

environmental fate characteristics. Because the livestock protection
14

collar is specifically designed to kill a wild mammal (coyote), wild

mammal toxicity testing has been required for sodium fluoroacetate.

Ward and Spencer (1947) determined the acute lethal doses

of sodium fluoroacetate for numerous mammalian species and

reported LD values as low as 0.1 mg/kg for both the cotton rat

50

(Sigmodon hispidus) and coyote (Canis latrans). They also reported

that the LD for the deer mouse (Peromyces sp.) was 4.0 mg/kg. 50

Beasom (1982) reported that the LD50 values for the opossum

(Didelphis virginiana) and raccoon (Procyon lotor) were 41.6 and

1.1 mg/kg, respectively. Atzert (1971) reported that the LD of 50s

sodium fluoroacetate to the striped skunk (Mephitus mephitus) and

opossum are 1 and 60 mg/kg, respectively. These data indicate that

sodium fluoroacetate can be classified as very highly toxic to

mammals on an acute oral basis. The guideline requirement for the

wild mammal toxicity test has been satisfied. Table 5 is a summary

for the acute toxicity of sodium fluoroacetate to mammals.

Table 5.

MAMMALIAN ACUTE TOXICITY DATA

Species LD mg/kg Conclusions 50

Coyote 0.1 highly toxic

Cotton rat 0.1 highly toxic

Deer mouse 4.0 highly toxic

Raccoon 1.1 highly toxic

Opossum 41.6 highly toxic

Skunk 1.0 highly toxic

(4) Insects

Data are not required on toxicity to insects, on the basis of

negligible exposure associated with the sodium fluoroacetate

livestock protection collar.

b. Toxicity to Aquatic Animals

(1) Freshwater Fish

In order to establish the toxicity of a pesticide to freshwater

fish, the minimum data required on the technical grade of the active

ingredient are two freshwater fish toxicity studies. One study
15

should use a coldwater species (preferably the rainbow trout), and

the other should use a warmwater species (preferably the bluegill

sunfish).

Collins (1993) reported that the 96-hour LC values of 50

technical grade sodium fluoroacetate to the rainbow trout

(Oncorhynchus mykiss) and bluegill sunfish (Lepomis macrochirus)

were 54 mg a.i./l and > 970 mg a.i./l, respectively. When no

substantial mortality occurs at the highest dose evaluated, the LC50

is reported as greater than that dose. Based on these data, sodium

fluoroacetate can be classified as slightly toxic to coldwater fish

species and practically non-toxic to warm water fish species. The

guideline requirements for freshwater fish toxicity tests have been

satisfied (MRID# 42961601, 42961602). Table 6 is a summary for

the toxicity of sodium fluoroacetate to freshwater fish.

Table 6.

FRESHWATER FISH ACUTE TOXICITY DATA

Species 96-hour LC (mg a.i./l) Conclusions 50

Rainbow trout 54 slightly toxic

Bluegill sunfish 970 practically non-toxic

(2) Freshwater Invertebrates

The minimum testing required to assess the toxicity of a

pesticide to freshwater invertebrates is a freshwater aquatic

invertebrate toxicity test, preferably using the first instar Daphnia

magna or early instar amphipods, stoneflies, mayflies, or midges

(Chironomus sp.).

Collins (1993) conducted an acute static toxicity test on

daphnids and determined that the 48-hour EC50 of sodium

fluoroacetate was 350 mg a.i./l (MRID# 42961603). Based on

these data, sodium fluoroacetate can be classified as practically nontoxic to freshwater invertebrates. The guideline requirement for the

freshwater toxicity test has been satisfied. Table 7 is a summary

for the toxicity of sodium fluoroacetate to freshwater invertebrates.

Table 7.

FRESHWATER INVERTEBRATE TOXICITY DATA 

Species 48-hour EC50 (mg a.i./l) Conclusions

Daphnia magna 350 practically non-toxic
16

(3) Estuarine and Marine Animals

Acute toxicity testing with estuarine and marine organisms

is required when an end-use product is intended for direct

application to the marine or estuarine environment or is expected to

reach that environment in significant concentrations. The terrestrial

non-food use of sodium fluoroacetate will not result in substantial

exposure to the estuarine environment. Therefore, these data are

not required.

c. Toxicity to Plants

Toxicity data are not required for terrestrial, semiaquatic, or aquatic

plants for sodium fluoroacetate because the chemical is not a herbicide, is

not applied aerially, and there is no other apparent basis for a phytotoxicity

concern.

2. Environmental Fate

The Agency has reviewed all literature submitted on environmental fate

properties, including studies not required for the livestock protection collar use.

No acceptable guideline studies for hydrolysis or other fate properties have been

submitted. Four published articles on environmental fate were submitted by the

Texas Department of Agriculture in support of an emergency exemption, and 13

published or unpublished articles were submitted in 1986 by the State of

California. These articles were found to be lacking significant data and of

uncertain value, and therefore not, acceptable as guideline studies. If any new uses

of sodium fluoroacetate are proposed, acceptable environmental fate studies may

be required.

a. Environmental Fate Assessment

The fate properties of the chemical are characterized to the extent

possible, recognizing the limitations of the available data. The conclusions

are very tentative relative to an evaluation that could be made if guideline

studies were available.

The limited data available suggest that leaching and metabolism are

the major routes of dissipation. However, undegraded fluoroacetate is

considered mobile and consequently has a high potential to move downward

in the soil and reach ground water.
17

Sodium fluoroacetate appears to degrade primarily by biologically

mediated processes. Sodium fluoroacetate appears first to ionize to sodium

and fluoroacetate with the fluoroacetate portion further degrading by

biologically mediated processes. Microorganisms capable of

dehalogenating compounds are reported to metabolize fluoroacetate to

fluoride and glycolate faster than other microorganisms. Unvalidated data

suggest that sodium fluoroacetate does not degrade substantially in 27 days

in sterile soil.

Because there are no leaching adsorption-desorption data, mobility

can only be assessed on the basis of solubility in water. Based on solubility

in water, undegraded fluoroacetate may tend to leach. However, the

potential for leaching may be reduced in some soils by adsorption to

organic matter and clay particles and absorption by plants. 

b. Environmental Fate and Transport

(1) Degradation

Hydrolysis (161-1)

 Three published articles have been submitted to the Agency

to support the hydrolysis data requirement. These articles were

found to be lacking significant data and of uncertain value, and

therefore, not acceptable to fulfill the hydrolysis guideline

requirement. However, the Agency is not requiring a new

hydrolysis study because of the limited amount of sodium

fluoroacetate that is used annually in the livestock protection

collars, as noted Section II.C. (MRID 00061751, 40016958,

40016959)

Based on one of these published articles the stability of

sodium monofluoroacetate in water and saline was determined for

a period of approximately 6 months. An immediate loss of fluorine

was detected in both the water and saline solutions. A progressive

loss of fluorine was reported in the water solutions. However, the

saline solutions indicated no significant decreases in fluorine content

after the initial loss. The chemical reaction was not further

addressed in the first of the articles by Goldman (MRID 00061751).

However, other articles indicate the following reaction:

XCH COO- + OH = HOCH COO- + X- 2 2

 (where X = F, Cl, or I) 
18

c. Water Resources

(1) Ground Water

For terrestrial uses, the published or unpublished data

indicate that small quantities of sodium fluoroacetate have the

potential to reach groundwater. The Agency's Pesticides in Ground

Water Database reports no detections for the period 1971 to 1991.

3. Exposure and Risk Characterization

a. Ecological Exposure and Risk Characterization

(1) Exposure and Risk to Nontarget Terrestrial Animals

Certain nontarget species of birds and mammals including

endangered and non-endangered species may be exposed by the

following mechanisms:

Primary hazard

Contaminated sheep or goat carcasses with either broken

(punctured) or unbroken collars.

Toxicant spilled on the ground or vegetation when a collar

is punctured.

Secondary hazard

Carcasses of coyotes killed by the sodium fluoroacetate

livestock protection collars and not removed.

Vomitus of poisoned coyotes. (The chemical has emetic

properties)

Based on a variety of studies that have been reviewed by the

Agency, the principal source of risk is exposure of scavengers

feeding on the head and neck area of dead livestock bearing the

sodium fluoroacetate livestock protection collars. The other sources

of exposure identified above are not likely to result in unacceptable

risk. Factors that reduce the risk associated with use of the sodium

fluoroacetate livestock protection collars include rapid

decomposition of carcasses, selective feeding of scavengers from
19

wounds on the carcass rather than contaminated skin surface of the

head or neck, and the emetic property of the chemical. The

concerns for risk to wildlife can be addressed with applicators

following environmental hazard statements, special use restrictions,

and endangered species protection statements that are required to be

placed on the label. 

The following is a review of information that applies to the

risks to both birds and mammals, which may be exposed by similar

mechanisms.

Risk from exposure to livestock carcasses bearing livestock

protection collars.

The information available suggests that the greatest risk to

nontarget species is from exposure to the neck areas of livestock

carcasses bearing the sodium fluoroacetate livestock protection

collars.

Knowlton and Ebbert (1991) used radiolabeled sodium

fluoroacetate as a physiological marker to determine the amount of

toxicant likely to be consumed by a coyote and the amount likely to

occur on the necks of collared goats (Capra sp.) when the coyotes

attacked the goats and punctured the collars that contained 30 ml of

the toxicant. The volume of fluid dispensed from the collar was

19.2 ml on average (range 11.9 to 27.8 ml); the average volume

ingested by the coyote was 1.0 ml (0.1 to 2.9 ml). The average

amount of toxicant contaminating the neck of the goat was 75 mg

(39 to 118 mg). The average amount of toxicant not recovered was

113 mg (0 to 234 mg). Once punctured, the pouches discharged

over 85% of their contents within a short time period. Relatively

little of the toxicant was actually ingested by the coyotes with 6 of

15 coyotes ingesting less than 5 mg when killing the goat.

Savarie et al. 1990 also studied contamination of the necks

of collared lambs (Ovis sp.) killed by coyotes. They found that 12

contaminated sheepskins contained an average of 96 mg sodium

fluoroacetate with a range of 23 to 200 mg.

Comparison of the two studies just cited (Knowlton and

Ebbert, 1991; Savarie et al. 1990) suggests that the amount of

toxicant on the necks of collared livestock is similar for goats and

sheep. The average amount of sodium fluoroacetate released from

the collar was 130 mg in the goat study (Knowlton and Ebert) and
20

135 mg for the sheep study (Savarie et al.). The amount not

recovered was 5.6 mg for the goat study and 6.1 mg in the sheep

study.

In the Knowlton and Ebbert study, the average amount of

fluid contaminating the neck of the goat was 7.5 ml (3.9 to 11.8

ml), or about 75 mg toxicant. That level clearly exceeds toxicity

values for numerous birds and mammals that could scavenge the

carcass, which suggests that the primary hazard to the scavengers

is quite high. However, field studies reviewed subsequently suggest

that mortality to scavengers feeding on the carcasses is actually

minor. For example, it has been observed that vultures, magpies,

ravens (Corvus corax), red-tailed hawks (Buteo jamaicensis),

caracaras (Polyborus cheriway), coyotes, and skunks all scavenged

the carcasses of collared livestock killed by coyotes, but none

appeared to have been poisoned (USDA/APHIS, 1991; Connolly,

1980; Littauer, 1983).

Several factors may account for the apparent discrepancy

between the field results and the implications of residue

measurements. First, the typical behavior of scavengers is to feed

at wounds or openings in the carcass or where the skin has been

torn away from the carcass, rather than on the contaminated neck

area. This tendency may greatly reduce the likelihood of exposure

to avian species such as the bald eagle (Haliaeetus leucocephalus)

(USFWS, 1984, 1985). Connolly (1980) simulated exposure to

non-target animals with a series of tests exposing magpies and

domestic dogs (Canis familiaris) to collared livestock killed by

coyotes. Both dogs and magpies fed heavily on the carcass but

neither were poisoned. Connolly further observed that both the

species tended to feed on parts where the coyote had previously fed

rather than on the neck area where the highest contamination is

likely. They concluded that typical feeding behavior of scavengers

confers a degree of protection against accidental poisoning by

livestock collars.

Secondly, toxicity data suggest that birds likely to scavenge,

particularly raptors, tend to be less sensitive to sodium fluoroacetate

than mammals, especially canids (Haegele et al., 1984; Ward and

Spencer, 1947 and Atzert, 1971). Also, emesis has been observed

as an early symptom of sodium fluoroacetate poisoning (Ward and

Spencer, 1947) and may cause certain raptors to discontinue feeding

before lethal amounts are absorbed (Dana, 1971). The emetic

property of sodium fluoroacetate is likely to reduce exposure to
21

raptors scavenging on livestock, and probably will also make the

raptors less likely to continue feeding on them.

Another factor that can greatly influence the primary hazard,

especially in warm weather, is that livestock carcasses decompose

rapidly under field conditions, rendering them unpalatable to many

avian and mammalian species (Burns et al., 1984 and Connolly,

1980).

Risk from lost or spilled toxicant

Knowlton and Ebbert (1991) found that the average volume

of fluid not recovered was 11.3 (0-23.4) ml or approximately 113

mg sodium fluoroacetate, which is nearly 33% of the total amount

in the 30 ml collar. It is believed that most of the fluid not

recovered is spilled on the ground. The available fate information

consists largely of studies that were not found to be acceptable.

Nevertheless the available information on fate properties suggests

that sodium fluoroacetate tends to be absorbed rapidly to organic

material and tends to degrade rapidly in soil. The Agency believes

that there is no substantial hazard to non-target organisms from the

sodium fluoroacetate that spills on the ground as a result of the

collar being punctured by an attacking coyote.

Risk from consumption of tissue, stomach contents, or vomitus of

coyotes killed by the sodium fluoroacetate livestock protection

collars

Connolly (1980) evaluated sodium fluoroacetate residues in

muscle of captive coyotes that received known oral doses. At a

known oral dose of 5.0 mg the concentration in muscle was

determined to be 0.10 ppm while the 10 mg dose resulted in a

concentration of 0.19 ppm. Based on this relationship a coyote that

ingests an average of 1 ml fluid (10 mg toxicant) will have muscle

tissue residues of 0.19 ppm sodium fluoroacetate. The highest

sodium fluoroacetate residue level found in muscle tissue was 0.93

ppm.

Residues in coyotes that have killed sheep wearing the 30 ml

collar have been determined by Burns et al. (1984). Those authors

report average concentrations of 0.15 ppm in muscle, 0.5 ppm in

stomach contents, and 0.35 ppm in vomitus. The highest residue

found occurred in the stomach contents and was 2.3 ppm.
22

Knowlton and Ebbert (1991) analyzed muscle tissue from 10

coyotes that were killed as a result of puncturing collars. Residues

were detected in the muscle of all the coyotes. The concentration

in muscle tissue was 0.089 ppm (range of 0.05 to 0.280 ppm); the

mean±SE sodium fluoroacetate lost from 12 collars was 92±56 mg

(range 3 to 183 mg).

Table 9 below gives estimates of the amount of muscle

tissue, stomach contents, or vomitus, from coyotes killed with the

30 ml sodium fluoroacetate livestock protection collar that would

have to be consumed in order for a scavenger to ingest an LD50

(Burns et al., 1984). These data suggest that secondary hazard to

to animals that may feed on a contaminated coyote carcass is

ordinarily not substantial (Burns et al., 1984; Connolly, 1980;

Knowlton and Ebbert, 1991). However, it is likely that carcasses

will occasionally contain enough sodium fluoroacetate to kill a

scavenger. The results below represent average exposures. The data

suggest substantial variation from one carcass to the next. This

qualification has to be considered when interpreting statements in

the following assessments related to muscle tissue, vomitus, and

stomach contents.

Table 9.

Approximate amounts of tissue from coyotes killed with the 30 ml sodium fluoroacetate livestock protection

collars that scavengers would have to consume to obtain an LD of sodium fluoroacetate. 50

Species Average LD LD dose Muscle 0.15 Stomach 0.5 Vomit 0.35

weight (kg) mg/kg (mg) ppm (kg) ppm (kg) ppm (kg)

50 50

Black 2.0 15.0 30 200 60 85.7

vulture

Golden 4.54 5.0 22.7 151 45.4 64.8 

Eagle

Black-Billed 0.18 1.0 0.18 1.2 0.36 0.51

Magpie

Coyote 11.4 0.1 1.14 7.6 2.28 3.25

Skunk 3.18 1.0 3.18 21.2 6.36 9.08

Muscle Tissue

Most species would have to consume considerable

contaminated tissue, relative to their body weight, to obtain a lethal

dose. For example, black vulture, golden eagle, and black-billed

magpie would have to consume 100×, 33×, and 6.6× their body
23

weights, respectively, to obtain an LD dose from muscle tissue. 50

Even a coyote, the most sensitive species tested, would have to eat

approximately 67% of its body weight to get an LD dose. 50

Stomach Contents

Black vulture, golden eagle, and black-billed magpie would

have to consume 30×, 10× and 2× their body weight,

respectively, to obtain an LD dose from stomach contents. 50

Because of the higher concentrations in stomach contents, species

that feed primarily on the viscera may be at greater risk than those

that feed primarily on muscle.

Vomitus

Clinical observations suggest that sodium fluoroacetate is

emetic especially to canids which have ingested more than an LD50

[Ward and Spencer, 1947 and Texas A&M University System

(TAMUS), 1983]. Observations of coyote behavior made during

the TAMUS study also found that some coyotes would cache the

vomitus, which may further reduce exposure to animals that would

otherwise eat it. Connolly (1980) reported that concentrations in

vomitus of four poisoned coyotes ranged from below the detection

limit (0.1 ppm) to 0.72 ppm. The average concentration in vomitus

from five coyotes that attacked sheep wearing the 30 ml collar has

been reported to be 0.35 ppm (USDA/APHIS, Unpublished Report,

1986). These levels may be toxic to certain species that are very

sensitive to sodium fluoroacetate; however, the Agency considers

it unlikely that sufficiently large amounts of vomitus would be

available or found by non-target animals under field conditions to

exceed the Agency's risk criteria. For example, the coyote would

have to consume about 29% of its body weight to obtain a LD50

equivalent from vomitus. The skunk would have to consume 280%

of its body weight.

Burns et al. (1986) also studied residues in coyotes killed

with single drop baits (SDBs) treated at 5 mg/bait. They found

average concentrations of 0.29 ppm for muscle, 0.30 ppm for small

intestine, and 0.31 ppm for stomach. They concluded that these

values were consistent with those found in the 30 ml sodium

fluoroacetate livestock protection collars study conducted by

Connolly (1980). They also conducted a series of feeding tests to

determine if there was any potential for secondary hazard to nontarget animals that fed on coyotes poisoned by the SDBs. All of the
24

removed tissue except the gastrointestinal tract was fed to 3 dogs

(Canis familiaris), 3 coyotes, 4 striped skunks and 15 magpies for

periods ranging from 14 to 35 days. The total amount of

contaminated tissue consumed, and expressed as percent of body

weight averaged 67% for dogs, 152% for coyotes, 117% for skunks

and 371% for the magpies. None of the test species exhibited any

signs of sodium fluoroacetate poisoning or had any detectable

sodium fluoroacetate residues in there tissues. Again, these data

indicate that even if non-target species feed on carcasses of coyotes

killed by the collar, it is highly unlikely that they will ingest

sufficient quantities of contaminated tissue to result in a secondary

hazard.

Finally, the U.S. Fish and Wildlife Service was required to

evaluate secondary hazard to non-target organisms resulting from

use of the 30 ml sodium fluoroacetate livestock protection collars.

To simulate secondary poisoning, coyotes were administered doses

of 4 mg, 100 mg, and 400 mg of sodium fluoroacetate. Upon

death, all the coyotes were skinned and eviscerated and all muscle

tissue was removed from the skeletons. All the tissue except the

gastrointestinal tract was ground up and fed to stripped skunks,

raccoons and opossums. The results indicated that only the

carcasses of animals that had received more than 200 mg of sodium

fluoroacetate would be expected to place scavengers at risk and that

the only species of scavengers that would be expected to be at risk

would be those with relatively low tolerance for the chemical

(TAMUS, 1983). The dosages that caused observable effects

greatly exceeded those administered to the coyote by the sodium

fluoroacetate livestock protection collars, indicating that mortality

to non-target animals is unlikely from operational use of the collar.

Total Collar Use

In addition to the residue information, it is important to

consider how many collars will typically be used in coyote control

operations. Based on the results of field studies conducted in

various states, it appears that the numbers of collars used and the

amounts of sodium fluoroacetate actually lost to the environment

are both quite low. For example, in the study conducted in New

Mexico only 23 of 330 of the collars (or 7%) were ever punctured.

Of those 23 collars only 5 (or 22%) were punctured by coyotes

(Littauer, 1991). The remaining 18 collars were punctured from

vegetation or unknown causes.
25

During three years of monitoring in Wyoming, Montana,

Texas, and New Mexico only 294 out of 2257 collars (13%) were

punctured and had their contents released. Assuming that each

collar was completely emptied, the amount of sodium fluoroacetate

released to the environment would be 88.2 grams, or an average of

29.4 grams/year over the four state area where the collars were

used. What is even more significant is that only 108 of the 294

collars punctured, or 36.7%, were punctured by coyotes. The total

amount of sodium fluoroacetate released from collars punctured by

coyote attacks (assuming that each collar was emptied) was 32.4

grams or an average of only 10.8 grams/year over the four state

area. Nearly as many collars (80 collars or 4%) were punctured

from vegetation and unknown causes as from coyote attacks.

Field Studies

From 1978 to 1980, the U.S. Fish and Wildlife Service

conducted field research in various states to assess primary and

secondary hazards from the use of the sodium fluoroacetate

livestock protection collars (Connolly, 1980). It was found that the

primary scavenger of collared goats that were killed by coyotes in

Texas were turkey vultures (Cartharista aura) and black vultures,

while red-tailed hawks, caracaras and ravens infrequently scavenged

kills. No scavenging by mammals was observed. In Montana and

Idaho, black-billed magpie was the species observed most

frequently as a scavenger of sheep killed by coyote. Scavenging by

ravens was observed infrequently. In addition the following

summary is given for primarly poisoning:

"In summary, coyote-killed collared livestock were known

to have been scavenged by turkey vultures, black vultures, magpies,

ravens, red-tailed hawks, caracaras, a skunk and a coyote during

the present studies. No scavenger was known or believed to have

been poisoned. Scavengers ignored the collars and fed instead upon

the viscera and muscle that has been exposed by the killer coyote."

Field observations of secondary poisoning studies, conducted

in Texas and Montana showed that turkey vultures were the only

scavengers of dead coyotes although numerous other scavengers

such as golden eagles, ravens, magpies, skunks and other potential

scavengers were abundant in the area.

From 1981 to 1983, the New Mexico Department of

Agriculture conducted an experimental field program evaluating the
26

efficacy and safety of the toxic collar. A total of 330 collars were

used over approximately 1,000 days. Twelve collared lambs were

attacked, but only 5 collars were actually punctured by predators.

A total of 18 collars were accidentally punctured while 21 collars

were lost. Three predators were found dead, two coyote and one

bobcat (Lynx rufus). The only non-target animal believed to have

been poisoned during the study was a skunk. The results of this

study suggest that exposure of non-target species by feeding on the

coyote carcass or the neck area of the collared livestock was low

and did not result in any significant adverse effects (Littauer, 1983).

As part of the registration requirements, the USDA/APHIS

was required to submit information on hazard to non-target species

resulting from the use of the 30 ml sodium fluoroacetate livestock

protection collars, collected as a result of use of the device in

Montana, Wyoming, New Mexico, South Dakota and Texas

(USDA/APHIS, 1991). The major findings from the actual use of

the collar during 1988, 1989 and 1990 as well as a report on the

field and laboratory research conducted from 1978 to 1980 are as

follows:

The contents of a small portion (13%) of the collars placed

on livestock were actually released into the environment.

The total amount of sodium fluoroacetate involved in the

release, assuming that each collar was completely emptied,

was 88.2 grams. This is an average of 29.4 grams/year

over the four state area where the collars were used. (No

collars were used in South Dakota.)

There were no reports of deaths of non-target animals

associated with the use of the sodium fluoroacetate livestock

protection collars during this period.

Only limited scavenging occurred on coyote carcasses.

Scavenging was reported by caracara and two species of

vulture.

Livestock carcasses were scavenged by vultures, magpies,

ravens, red-tailed hawks, caracaras, skunks and coyotes, but

none of these non-target species were known to have been

poisoned as a result.

Scavenger species tended to feed mainly on viscera and

muscle of hind quarters.
27

Of the 13% of the collars that had their contents released

during the time period (or 294 collars), only 5% (108

collars) were punctured by coyotes.

(a) Birds

The chemical is very highly toxic to birds on an

acute oral basis. Certain bird species may be exposed,

primarily as a result of scavenging the carcasses of livestock

bearing the sodium fluoroacetate livestock protection

collars. The risks are discussed in detail above, generically

for nontarget avian scavengers and nontarget mammalian

scavengers. The concerns for risk to wildlife can be

addressed with the environmental hazard statements, special

use restrictions, and endangered species protection

statements, that are required to be placed on the label.

(b) Mammals

The chemical is very highly toxic to mammals on an

acute oral basis. Certain species may be exposed, primarily

as a result of scavenging the carcasses of livestock bearing

the sodium fluoroacetate livestock protection collars. The

risks are discussed in detail above, generically for nontarget

avian scavengers and nontarget mammalian scavengers.

The concerns for risk to wildlife can be addressed with

environmental hazard statements, special use restrictions,

and endangered species protection statements, that are

required to be placed on the label.

(c) Insects

Substantial exposure of nontarget insects is not

anticipated from the use of the sodium fluoroacetate

livestock protection collars.

(2) Exposure and Risk to Nontarget Aquatic Animals

Based on low toxicity to aquatic animals and low exposure

associated with use of the sodium fluoroacetate livestock protection

collars, the Agency finds that use of the collar is not likely to result

in unacceptable risk. Sodium fluoroacetate is practically non-toxic

to warmwater fish species and aquatic invertebrates, and only
28

slightly toxic to coldwater fish species. The Agency does not have

reports of detections in surface or ground water.

(3) Exposure and Risk to Nontarget Plants

Evaluation of exposure and risk is not required for

terrestrial, semiaquatic, or aquatic plants because sodium

fluoroacetate is not a herbicide and is not applied aerially, and there

is no other apparent basis for a phytotoxicity concern.

(4) Endangered Species

On March 21, 1985, the Agency requested formal Section

7 consultation relative to the United States Department of Interior's

application to register compound sodium fluoroacetate livestock

protection collar. On June 14, 1985, the U. S. Fish and Wildlife

Service - Office of Endangered Species (USFWS-OES) responded

and concluded that the use of the sodium fluoroacetate collar with

proposed use directions and restrictions posed no jeopardy to the

bald eagle, San Joaquin kit fox, black-footed ferret (Mustela

nigripes), and gray wolf (Canis lupus), but was likely to jeopardize

the continued existence of the grizzly bear (Ursus arctos horribilus),

Rocky Mountain wolf (Canis lupus irremotus) and California

condor (Gymnogys californianus) (USFWS, 1985). The USFWSOES provided specific state and county recommendations for

avoiding adverse effects to the non-jeopardy species as well as

reasonable and prudent alternatives for precluding jeopardy to the

three species in jeopardy from the use pattern. Based on these

recommendations, the Agency developed specific endangered

species label precautions and use restrictions for the 30 ml collar.

These use restrictions have been included in a Technical Bulletin

that accompanies the labeling.

In 1987, as a result of informal consultation with field

operations personnel from the USFWS, the Agency became aware

that additional precautions, specifically addressing the use of the

sodium fluoroacetate livestock protection collars in Texas, were

required to protect the ocelot (Felis pardalis) and jaguarundi (Felis

yagouarundi cacomitei) (USFWS, 1986). The additional use

precautions were reviewed by the Agency and included in the

Technical Bulletin.
29

In March 1993 the USFWS issued a final biological opinion

on the effects of 16 vertebrate control agents on threatened and

endangered species. This opinion specifically addressed the

livestock protection collar and included jeopardy determinations to

the gray wolf and grizzly bear. It did not conclude jeopardy

determinations to any other species. The USFWS identified specific

areas where the collar could not be used and concluded that

implementation of such a restriction would preclude jeopardy to

both the graph wolf and the grizzly and that no incidental take

would occur from the use of the collar. Such restrictions have been

incorporated on the livestock protection collar labels.

IV. RISK MANAGEMENT AND REREGISTRATION DECISION

A. Determination of Eligibility

Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission

of relevant data concerning an active ingredient, whether products containing the active

ingredients 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 sodium fluoroacetate active ingredients. 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 sodium fluoroacetate.

Appendix B identifies the generic data requirements that the Agency reviewed as part of

its determination of reregistration eligibility of sodium fluoroacetate, and lists the

submitted studies that the Agency found acceptable.

The data identified in Appendix B were sufficient to allow the Agency to assess the

registered uses of sodium fluoroacetate and to determine that sodium fluoroacetate can be

used without resulting in unreasonable adverse effects to humans and the environment.

The Agency, therefore, finds that all products containing sodium fluoroacetate as the

active ingredients are eligible for reregistration. The reregistration of particular products

is addressed in Section V of this document. 

The Agency made its reregistration eligibility determination based upon the target

data base required for reregistration, the current guidelines for conducting acceptable

studies to generate such data, published scientific literature, etc. and the data identified in

Appendix B. Although the Agency has found that all currently registered uses of sodium

fluoroacetate are eligible for reregistration, it should be understood that the Agency may

take appropriate regulatory action, and/or require the submission of additional data to

support the registration of products containing sodium fluoroacetate if new information

comes to the Agency's attention or if the data requirements for registration (or the

guidelines for generating such data) change.
30

As described in the Regulatory History and Status section of this document (Section

II.E.), and in 40 CFR Part 164, Subpart D, new predicidal uses for sodium fluoroacetate

cannot be granted without submission by the applicant of new evidence which was not

available and which could have impacted the outcome of the decision in 1972 by the

Administrator to cancel the predicidal uses, and without a hearing involving all interested

parties. 

1. Eligibility Decision

Based on the reviews of the generic data for the active ingredient sodium

fluoroacetate, the Agency has sufficient information on the health effects of sodium

fluoroacetate and on its potential for causing adverse effects in fish and wildlife

and the environment. 

The Agency has determined that sodium fluoroacetate products, labeled and

used as specified in this Reregistration Eligibility Decision, will not pose

unreasonable risks or adverse effects to humans or the environment. Therefore, the

Agency concludes that products containing sodium fluoroacetate registered for the

sole remaining use are eligible for reregistration.

2. Eligible and Ineligible Uses 

The Agency has determined that the single currently registered use of

sodium fluoroacetate is eligible for reregistration.

B. Regulatory Position

The following is a summary of the regulatory positions and rationales for sodium

fluoroacetate. Where labeling revisions are imposed, specific language is set forth in

Section V of this document.

1. Restricted Use Classification

Sodium fluoroacetate, which is only registered for use in livestock

protection collars, will retain the restricted use classification imposed by the

Agency in 1978 due to its high acute toxicity and the need for highly specialized

applicator training.

2. Endangered Species Statement

The Agency has concerns about the exposure of threatened and endangered

animal species to sodium fluoroacetate as discussed above in the science assessment

chapter.
31

At this time no further measures are necessary for protection of endangered

species. Should the use of sodium fluoroacetate change or the Agency becomes

aware of new information that would warrant new concerns, the Agency will take

additional action as necessary.

V. ACTIONS REQUIRED OF REGISTRANTS

This section specifies the data and labeling requirements and responses necessary for the

reregistration of both manufacturing-use and end-use products.

A. Manufacturing-Use Products

1. Additional Generic Data Requirements

The generic data base supporting the reregistration of sodium fluoroacetate

for the above eligible use has been reviewed and determined to be substantially

complete.

2. Labeling Requirements for Manufacturing-Use Products

To remain in compliance with FIFRA, manufacturing use product (MP)

labeling must be revised to comply with all current EPA regulations, PR Notices

and applicable policies. The MP labeling must bear the following statement under

Directions for Use:

"For use only for reformulating into sodium fluoroacetate solutions for use only

in Federally-registered livestock protection collars".

B. End-Use Products

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 product specific data requirements are listed in Appendix G, the

Product Specific Data Call-In Notice.

Registrants must review previous data submissions to ensure that they meet

current EPA acceptance criteria (Appendix F; Attachment E) and if not, commit

to conduct new studies. If a registrant believes that previously submitted data meet

current testing standards, then study MRID numbers should be cited according to

the instructions in the Requirement Status and Registrants Response Form provided

for each product.
 "Direct Supervision," as described in this restriction, conforms to the requirements 1

established under 40 CFR 171.6. 

32

2. Labeling Requirements for End-Use Products

The use of sodium fluoroacetate in the animal protection collar is currently

registered in five states (Montana, New Mexico, South Dakota, Texas, and

Wyoming).

The following list of use restrictions for sodium fluoroacetate represents the

USDA/APHIS product.

The labels and labeling of all products must comply with EPA's current

regulations and requirements as specified in 40 CFR §156.10 and other applicable

notices.

USE RESTRICTIONS

1. Use of livestock protection (LP) collars shall conform to all applicable

Federal, State, and local regulations.

2. LP Collars shall be sold or transferred only by registrants or their agents

and only to certified Livestock Protection Collar applicators. Collars may

be used only by specifically certified Livestock Protection Collar

applicators or by persons under their direct supervision. 1

The certified applicator is directly responsible for assuring that all use

restrictions are met. The certified applicator will decide, in accordance

with label directions, when and under what circumstances collars will be

used. The certified applicator will either apply collars or be physically

present where collars are applied by a noncertified person. However, a

noncertified person who has received adequate instructions from the

certified applicator may store collars, check collars in the field, remove

collars, repair or dispose of damaged collars in accordance with use

restrictions, retrieve collars laying in the field and properly dispose of

contaminated material and animal carcasses.

3. Certification of applicators shall be performed by appropriate regulatory

agencies. Prior to certification, each applicator shall receive training which

will include, but need not be limited to:

(a) Training in safe handling and attachment of LP collars. 
33

(b) Trainig in disposal of punctured or leaking LP collars, and

contaminated animal remains, vegetation, soil, and clothing. 

(c) Instructions for practical treatment of 1080 poisoning in humans

and domestic animals. 

(d) Instructions on record keeping.

4. Registrants or their agents shall keep records of all collars sold or

transferred at their address of record. Records shall include the name,

address, state where Livestock Protection Collar certification was issued,

certification number of each recipient, and dates and numbers of collars

sold or transferred.

5. Each applicator shall keep records dealing with the use of LP Collars and

the results of such use. Records shall be maintained in accordance with

appropriate State or Federal regulations but for not less than two years

following disposal or loss of collar. Such records shall include, but need

not be limited to:

(a) The number of LP collars attached on livestock. 

(b) The pasture(s) where LP collared livestock were placed.

(c) The dates of each attachment, inspection, and removal

(d) The number and locations of livestock found with ruptured or

punctured LP collars and the apparent cause of the damage.

(e) The number, dates, and approximate location of LP collars lost.

(f) The species, locations, and dates of all suspected poisonings of

humans, domestic animals or non-target wild animals resulting from

LP collar use.

6. Any suspected poisoning of threatened or endangered species must be

reported immediately (within three days) to the Environmental Protection

Agency, as will each suspected poisoning of humans, domestic animals or

non-target wild animals. The person to contact at the Environmental

Protection Agency is Robert A. Forrest (PM-14), Registration Division

(7505C), 401 M Street, SW, Washington, DC 20460.

7. Only the registrant or collar manufacturer is authorized to fill LP collars

with 1080 solution. Certified applicators are not authorized to fill LP

collars. Compound 1080 solution may not be removed from collars and

used for any other purpose.
 Fenced pastures include all grazing land that is enclosed by livestock fencing. This includes 2

wire or other man-made fences such as rock walls, and natural barriers such as escarpments,

lakes, and large rivers that will prevent the escape of livestock. 

34

8. LP Collars shall only be used to take coyotes within fenced pastures no

2

larger than 2,560 acres (4 square miles). But where average annual

precipitation does not exceed 20 inches and vegetation is sparse, consisting

only of short to mid-height grasses and scattered shrubs, collars may be

used in pastures up to a maximum of 10,000 acres (16 square miles) in

size.

In no case shall the applicator place LP collared livestock in pastures where

compliance with other Use Restrictions, such as monitoring, is impossible; in

fenced pastures larger than 10,000 acres; or in unfenced, open range.

9. LP Collars shall be used only where losses of sheep or goats due to

predation by coyotes are occurring or, based upon prior experience, where

coyote predation can reasonably be expected to occur.

 10. Where LP collars are in use, each logical point of access (for example,

roads, gates, and trails) shall be conspicuously posted with a bilingual

(English/Spanish or other second language appropriate for the region)

warning sign not less than 8" X 10" in size. Signs shall be inspected weekly

to ensure their continued presence and legibility and will be removed when

collars are removed. The signs will have a minimum type size for

"DANGER-POISON" of 24 point (1/4 inches), with remaining text at least

18 point (3/16 inches).

11. All LP collared livestock must be checked at least once every seven days

and collars adjusted if needed.

If any LP collared animal is not accounted for in two consecutive checks,

an intensive search for it must be made. 

In addition, if more than three LP collared animals are not accounted for

during any one check, an intensive search for these animals is required.

If more than nine (9) LP collars are unaccounted for during any 60 day

period, remove all collars from animals and terminate their use. Do not

resume use until adequate steps have been taken to prevent further,

excessive loss of collars. 
35

12. Damaged, punctured, or leaking LP collars shall be removed from the field

for repair or proper disposal. Damaged collars shall be placed individually

in leakproof containers while awaiting repair or proper disposal.

Authorized collar repairs are limited to minor repairs of straps and

fastenings. Leaking or punctured collars must be properly disposed.

13. Dispose of 1080 wastes (punctured, leaking, or otherwise unrepairable LP

collars; contaminated leather clothing, animal remains, wool, hair,

vegetation, water, and soil) under three feet of soil, at a safe location,

preferably on property owned or managed by the applicator and at least 1/2

mile from human habitations and water supplies. No more than 10 collars

may be buried in any one hole. lf buried in a trench, each group of 10

collars must be at least 10 feet apart.

Incineration may be used instead of burial for disposal in the field

(preferably on property owned or managed by the applicator) at least 1/2

mile from human habitation and water supplies. Place collars and waste

(listed above) in an incinerator or refuse hole, saturate with diesel fuel, and

ignite. Attend the burn until the contaminated material is completely

consumed.

Alternatively, contact your State Pesticide or Environmental Control

Agency or the Hazardous Waste representative at the nearest EPA Regional

Office for guidance in disposing of wastes at approved hazardous waste

disposal facilities.

When snow or frozen ground make on-site disposal impractical, up to one

cubic foot of wastes may be stored in a leak-proof container in a dry,

locked place for 90 days.

Metal Container: Triple rinse contaminated and uncontaminated containers

with water. Puncture and dispose of contaminated container and rinsate as

above.

Plastic Container: Triple rinse with water. Then puncture and dispose of

container and rinsate as above.

14. All persons authorized to possess and use LP Collars shall store them under

lock and key in a dry place away from food, feed, domestic animals, and

corrosive chemicals and in outbuildings, or in outdoor storage areas

attached to, but separate from human living quarters.
36

15. Provisions for the protection of endangered species:

The LP Collar may not be used in the following areas due to potential

adverse effects to endangered species (California condor). 

 

 STATE COUNTIES 

 

 California Fresno, Kern, Kings, Los Angeles, Monterey, San

Luis Obispo, Santa Barbara, Tulare, and Ventura

The LP collar may not be used in the following areas without written approval

from the nearest U.S. Fish and Wildlife Service Office (FWS, Endangered Species

Specialists). If FWS or the user determines that the use of collars may adversely

impact an endangered species (San Joquin kit fox, black-footed ferret, Northern

 Rocky Mountain wolf, or Grizzly bear) in the specific areas requested, collars

may not be used in these areas. Written approval must be obtained annually.

State Counties or Area NEAREST FWS 

OFFICE/

PHONE 

 

California Alameda, Contra Costa, Sacramento, CA

Merced, San Joaquin, 916-978-4866

Santa Clara, and Satnislaus

Idaho Bonner, Boise (north of Boise, ID

State Highway 21), 208-334-1931

Boundry, Clearwater,

Custer (north of local road

running from Sun Valley to

Chilly and a corresponding

line northeast from Chilly

to Patterson), Fremont,

Idaho, Lemhi, Shosshone,

and Valley

Michigan Keweenaw (Isle Royal) and Twin Cities, MN

entire Upper Peninsula 612-725-3276
State Counties or Area NEAREST FWS 

OFFICE/

PHONE 

 

37

Minnesota Aitkin, Becker, Beltrami, Twin Cities, MN

Carlton, Cass, Clearwater, 612-725-3276

Cook, Crow Wing,

Hubbard, Itasca, Kittson,

Koochiching, Lake, Lake

of the Woods, Mahnomen,

Marshall, Pennington, Pine

Roseau, and St. Louis

 

Montana Beaverhead, Carbon, Helena, MT

Flathead, Gallatin, Glacier, 406-449-5322

Lake, Lewis and Clark,

Lincoln, Madison,

Missoula, Park, Pondera,

Powell, Sanders,

Stillwater, Sweet Grass,

and Teton 

 

Washington Pend Orielle, Okanogan, Boise, ID

(National Park and Forrest 208-334-1931

Land), Skagit, and

Whatcom

Wisconsin Douglas, Florence, Twin Cities, MN

Lincoln, Oneida, and Price 612-725-3276

Wyoming Fremont, Park, and Teton Helena, MT

and Yellowstone National 406-449-5322

Parks

 

16. The number of LP collars used shall be the minimum necessary for

effective livestock protection. For pastures of the following size classes, do

not use more collars than the number indicated.

 

Size (acres) Number of Collars

 up to 100 20

 101 to 640 50

 641 to 10,000 100
38

17. Each applicator will have a one-ounce bottle of syrup of ipecac (to induce

vomiting in case of accidental poisoning) available when attaching,

inspecting, removing, or disposing of LP collars.

18. No contaminated animal will be used for food or feed.

In addition, for State-limited products, additional use restrictions consistent with

EPA's regulatory position and legal decisions regarding predacidal uses of sodium

fluoroacetate may be added. The organization of restrictions may be altered so as to

maintain consistency with applicable State and Federal laws and regulations but no

requirements may be dropped or mitigated. Any changes to the use restrictions must be

requested through the amendment process and must be accepted by the U.S.

Environmental Protection Agency before they may be incorporated into the labeling of

product released for shipment in the U.S.

Unless the Agency specifically indicates otherwise, the current accepted labeling

for registered 1080 Livestock Protection Collar products remains acceptable.

The registrants should submit 5 copies of their last accepted labeling (all 3

componets thereof) with their 8-months responses. The Agency will then review the

documents to determine whether any changes are needed.

 

C. Existing Stocks

Registrants may generally distribute and sell products bearing old labels/labeling

for 26 months from the date of the issuance of this Registration Eligibility Decision

(RED). Persons other than the registrant may generally distribute or sell such products

for 50 months from the date of the issuance of this RED. However, 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. Refer to "Existing Stocks of Pesticide

Products; Statement of Policy"; Federal Register, Volume 56, No. 123, June 26, 1991.

The Agency has determined that registrants may distribute and sell sodium

fluoroacetate products bearing old labels/labeling, i.e., labels absent the modifications

specified in this RED document, except as noted below, for 26 months from the date of

issuance of this RED. Registrants and persons other than the registrants remain obligated

to meet preexisting Agency imposed label changes and existing stocks requirements

applicable to your products. 
39

VI. APPENDICES
40

APPENDIX A. Table of Use Patterns Subject to Reregistration

Report Run Date: 05/01/95 ) Time 12:06 APPENDIX A ) CASE 3073, [Fluoroacetic acid derivs.] Chemical 075003 [Sodium fluoroacetate] LUIS 2.0 ) Page 1

PRD Report Date: 01/20/95 

4444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444

SITE Application Type, Application Form(s) Min. Appl. Max. Appl. Soil Max. # Apps Max. Dose [(AI Min. Restr. Geographic Limitations Use

 Timing, Application Equipment ) Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed Limitations

 Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise)/A] (days) Interv Codes

 cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]

 cycle

USES ELIGIBLE FOR REREGISTRATION

FOOD/FEED USES

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

DAIRY GOATS (LACTATING OR UNSPECIFIED) Use Group: INDOOR FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

GOATS (MEAT) Use Group: INDOOR FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar
41

Report Run Date: 05/01/95 ) Time 12:06 APPENDIX A ) CASE 3073, [Fluoroacetic acid derivs.] Chemical 075003 [Sodium fluoroacetate] LUIS 2.0 ) Page 2

PRD Report Date: 01/20/95 

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SITE Application Type, Application Form(s) Min. Appl. Max. Appl. Soil Max. # Apps Max. Dose [(AI Min. Restr. Geographic Limitations Use

 Timing, Application Equipment ) Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed Limitations

 Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise)/A] (days) Interv Codes

 cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]

 cycle

USES ELIGIBLE FOR REREGISTRATION

FOOD/FEED USES (con't)

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

GOATS (MEAT) (con't) Use Group: INDOOR FOOD (con't)

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

KIDS (MEAT) Use Group: INDOOR FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

LAMB (MEAT) Use Group: INDOOR FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar
42

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PRD Report Date: 01/20/95 

4444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444

SITE Application Type, Application Form(s) Min. Appl. Max. Appl. Soil Max. # Apps Max. Dose [(AI Min. Restr. Geographic Limitations Use

 Timing, Application Equipment ) Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed Limitations

 Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise)/A] (days) Interv Codes

 cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]

 cycle

USES ELIGIBLE FOR REREGISTRATION

FOOD/FEED USES (con't)

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

LAMB (MEAT) (con't) Use Group: INDOOR FOOD (con't)

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

SHEEP (MEAT) Use Group: INDOOR FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

NON-FOOD/NON-FEED

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

GOATS (WOOL/ANGORA ANIMAL) Use Group: INDOOR NON-FOOD
43

Report Run Date: 05/01/95 ) Time 12:06 APPENDIX A ) CASE 3073, [Fluoroacetic acid derivs.] Chemical 075003 [Sodium fluoroacetate] LUIS 2.0 ) Page 4

PRD Report Date: 01/20/95 

4444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444

SITE Application Type, Application Form(s) Min. Appl. Max. Appl. Soil Max. # Apps Max. Dose [(AI Min. Restr. Geographic Limitations Use

 Timing, Application Equipment ) Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed Limitations

 Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise)/A] (days) Interv Codes

 cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]

 cycle

USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED (con't)

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

GOATS (WOOL/ANGORA ANIMAL) (con't) Use Group: INDOOR NON-FOOD (con't)

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar

SHEEP Use Group: INDOOR NON-FOOD

Animal treatment (rubber bladder collar)., FM/L NA 6.650E-04 lb * NS NS NS NS NS NS 013 C20, CAL

When needed., Glove. collar Geo.013: The collar may not be used in the following California counties due to potential

 adverse effects to endangered species (California condor): Fresno, Kern, Kings, Los

 Angeles, Monterey, San Benito, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The

 collar may be used in various counties (see label for specific counties) of the following

 states: California, Idaho, Michigan, Minnesota, Montana, Washington, Wisconsin, and

 Wyoming. Written approval, on an annual basis, must be obtained from the U.S. Fish and

 Wildlife Service Office prior to use in these states.

 FM/L NA 6.650E-04 lb * NS NS NS NS NS NS MT C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS NM C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS SD C20, CAL

 collar

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS TX C20, CAL

 collar
44

Report Run Date: 05/01/95 ) Time 12:06 APPENDIX A ) CASE 3073, [Fluoroacetic acid derivs.] Chemical 075003 [Sodium fluoroacetate] LUIS 2.0 ) Page 5

PRD Report Date: 01/20/95 

4444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444

SITE Application Type, Application Form(s) Min. Appl. Max. Appl. Soil Max. # Apps Max. Dose [(AI Min. Restr. Geographic Limitations Use

 Timing, Application Equipment ) Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed Limitations

 Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise)/A] (days) Interv Codes

 cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]

 cycle

USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED (con't)

)))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

SHEEP (con't) Use Group: INDOOR NON-FOOD (con't)

 FM/L NA 6.708E-04 lb * NS NS NS NS NS NS WY C20, CAL

 collar
45

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PRD Report Date: 01/20/95 

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LEGEND

444444

 HEADER ABBREVIATIONS

 Min. Appl. Rate (AI unless : Minimum dose for a single application to a single site. System calculated. Microbial claims only.

 noted otherwise)

 Max. Appl. Rate (AI unless : Maximum dose for a single application to a single site. System calculated.

 noted otherwise)

 Soil Tex. Max. Dose : Maximum dose for a single application to a single site as related to soil texture (Herbicide claims only).

 Max. # Apps @ Max. Rate : Maximum number of Applications at Maximum Dosage Rate. Example: "4 applications per year" is expressed as "4/1 yr"; "4 applications per 3 

 years" is expressed as "4/3 yr" 

 Max. Dose [(AI unless : Maximum dose applied to a site over a single crop cycle or year. System calculated.

 noted otherwise)/A]

 Min. Interv (days) : Minimum Interval between Applications (days)

 Restr. Entry Interv (days) : Restricted Entry Interval (days)

 PRD Report Date : LUIS contains all products that were active or suspended (and that were available from OPP Document Center) as of this date. Some products

 registered after this date may have data included in this report, but LUIS does not guarantee that all products registered after this date have

 data that has been captured.

 SOIL TEXTURE FOR MAX APP. RATE

 * : Non-specific

 C : Coarse

 M : Medium

 F : Fine

 O : Others

 FORMULATION CODES

 FM/L : FORM NOT IDENTIFIED/LIQUID

 ABBREVIATIONS 

 AN : As Needed

 NA : Not Applicable

 NS : Not Specified (on label)

 UC : Unconverted due to lack of data (on label), or with one of following units: bag, bait, bait block, bait pack, bait station, bait station(s), block, briquet, 

 briquets, bursts, cake, can, canister, capsule, cartridges, coil, collar, container, dispenser, drop, eartag, grains, lure, pack, packet, packets, pad, part, 

 parts, pellets, piece, pieces, pill, pumps, sec, sec burst, sheet, spike, stake, stick, strip, tab, tablet, tablets, tag, tape, towelette, tray, unit, -- 

 

 APPLICATION RATE

 DCNC : Dosage Can Not be Calculated

 No Calc : No Calculation can be made

 W : PPM calculated by weight

 V : PPM Calculated by volume

 U : Unknown whether PPM is given by weight or by volume

 cwt : Hundred Weight

 nnE-xx : nn times (10 power -xx); for instance, "1.234E-04" is equivalent to ".0001234"

 USE LIMITATIONS CODES

 C20 : Endangered species restriction.

 CAL : Do not contaminate water, food or feed.

 * NUMBER IN PARENTHESES REPRESENTS THE NUMBER OF TIME UNITS (HOURS,DAYS, ETC.) DESCRIBED IN THE LIMITATION.

 GEOGRAPHIC CODES

 013 : Other

 MT : Montana

 NM : New Mexico
46

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PRD Report Date: 01/20/95 

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 GEOGRAPHIC CODES (Cont.)

 SD : South Dakota

 TX : Texas

 WY : Wyoming
47

APPENDIX B. Table of the Generic Data Requirements and Studies Used to Make the

Reregistration Decision GUIDE TO APPENDIX B

Appendix B contains listings of data requirements which support the reregistration for active

ingredients within the case SODIUM FLUOROACETATE covered by this Reregistration

Eligibility Decision Document. It contains generic data requirements that apply to SODIUM

FLUOROACETATE in all products, including data requirements for which a "typical

formulation" is the test substance.

The data table is organized in the following format:

1. Data Requirement (Column 1). The data requirements are listed in the order in which

they appear in 40 CFR Part 158. the reference numbers accompanying each test refer to the test

protocols set in the Pesticide Assessment Guidelines, which are available from the National

Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703) 487-4650.

2. Use Pattern (Column 2). This column indicates the use patterns for which the data

requirements apply. The following letter designations are used for the given use patterns:

A Terrestrial food

B Terrestrial feed

C Terrestrial non-food

D Aquatic food

E Aquatic non-food outdoor

F Aquatic non-food industrial

G Aquatic non-food residential

H Greenhouse food

I Greenhouse non-food

J Forestry

K Residential

L Indoor food

M Indoor non-food

N Indoor medical

O Indoor residential

3. Bibliographic citation (Column 3). If the Agency has acceptable data in its files, this

column lists the identifying number of each study. This normally is the Master Record

Identification (MRID) number, but may be a "GS" number if no MRID number has been

assigned. Refer to the Bibliography appendix for a complete citation of the study.
48

 APPENDIX B

Data Supporting Guideline Requirements for the Reregistration of Sodium Fluoroacetate

REQUIREMENT USE PATTERN CITATION(S)

PRODUCT CHEMISTRY

61-1 Chemical Identity LM 41216101

61-2A Start. Mat. & Mnfg. Process LM 42127401

61-2B Formation of Impurities LM 41216101

62-1 Preliminary Analysis LM 41631701

62-2 Certification of limits LM 41631702

62-3 Analytical Method LM 41631704

63-2 Color LM 42678801

63-3 Physical State LM 42678802

63-4 Odor LM 42678803

63-5 Melting Point LM 41171102

63-7 Density LM 41171103

63-10 Dissociation Constant LM 41171102

63-12 pH LM 41171103

63-13 Stability LM 42678804

63-17 Storage stability LM 41631703

ECOLOGICAL EFFECTS

71-1A Acute Avian Oral - Quail/Duck LM *

71-2A Avian Dietary - Quail LM 43210601

71-2B Avian Dietary - Duck LM 43210602

71-5A Simulated Field Study LM 41958701

71-5B Actual Field Study LM 41514901

72-1A Fish Toxicity Bluegill LM 42961601

72-1C Fish Toxicity Rainbow Trout LM 42961602

72-2A Invertebrate Toxicity LM 42961603

TOXICOLOGY

81-1 Acute Oral Toxicity LM 40016971, 65627, *

81-2 Acute Dermal Toxicity LM 152129

81-3 Acute Inhalation Toxicity LM Waived

81-4 Primary Eye Irritation - Rabbit LM 40402603
Data Supporting Guideline Requirements for the Reregistration of Sodium Fluoroacetate

REQUIREMENT USE PATTERN CITATION(S)

49

81-5 Primary Dermal Irritation - Rabbit LM 40402604

81-6 Dermal Sensitization LM Waived

82-1(a) 90-Day Feeding - Rodent LM 40016990, *

85-1 General Metabolism LM *

ENVIRONMENTAL FATE

161-1 Hydrolysis LM 61751, 40016958, 40016959

*See Appendix C, Bibliography for citations from the published literature
50

APPENDIX C. Citations Considered to be Part of the Data Base Supporting the

Reregistration of Sodium Fluoroacetate

GUIDE TO APPENDIX C

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 (19??),

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,
51

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.
BIBLIOGRAPHY

MRID CITATION

______________________________________________________

52

--------- Beasom, S. L., (1982). Report on-Efficacy of the 1080 toxic collarsas a predator

damage control method (July 1, 1982 -September 30,1982). Texas A & M

University, College Station, Texas. 

--------- Burns R. J., Connolly, G. E. and Okuno, I. (1986). Secondary toxicity of coyotes

killed by 1080 single-dose baits. Denver Wildlife Research Center, USDA/APHIS.

Proc. 12th Vertebrate Pest Conf, San Diego, California. p324-329.

--------- Burns, R.J. and G.E. Connolly 1992. Toxicity of Compound 1080 to Magpies

and the Relationship of Dose Rates to Residues Recovered. USDA, Denver

Wildlife Research Center. Proc. 15th Vertebrate Pest Conf., Newport Beach, Ca.

p403 (6).

--------- Dana, R. H. 1971. Vertebrate pest control in California. Unpublished mimeo. rep.

California Dept. of Agriculture. 14 pp. 

-------- Ghali, G. 1994. RfD/Peer Review Report of Sodium Fluoroacetate. U.S. EPA

memorandum.

-------- Gribble, G. 1973. Fluoroacetate Toxicity. J. Chem. Educ. 50:460-2.

-------- Hegdal, P. L., T.A. Gatz, K. A. Fagerstone, J.F. Glahn and G. H.Matschke.

(1979). Hazards to wildlife associated with 1080 baiting for California ground

squirrels.

-------- Hilton, H. W., Q.H. Yuen, and N.S. Nomura. 1969. Absorption of

monofluoroacetate-2C ion and its translocation in sugarcane. J.Agric. Food Chem.

17:131-134.

-------- Hudson, R. K., R. K. Tucker, and M. A. Haegele, 1984. Handbook of toxicity

of pesticides to wildlife, 2nd edition. U.S. Dept. ofInterior, Fish and Wildlife

Service, Resource Publication 153, Washington, D.C. 90 pp.

-------- Knowlton, F.F., and S.M. Ebbert. 1991. Develop physiologic markersto identify

coyotes that kill sheep or goats (Unpublished report to the EPA - QA-090)

USDA/APHIS, Denver Wildlife Research Center,Denver, Colorado. 27 pp.

-------- Sax, N. I., and Lewis, R. J. SR, (1989) Dangerous Properties of Industrial

Materials, 7th Ed. Van Nostrand Reinhold, NY.

-------- TAMUS (Texas A&M University System). 1983. Efficacy of the 1080 toxic collar

as a predator damage control method. Final report tothe U.S. Fish and Wildlife

Service for Cooperative Research Project No. 14-16-0009-81-934, September 1,

1980-June 30, 1983. Department of Wildlife and Fisheries Sciences, Texas

Agricultural Experiment Station. Data report submitted to the Environmental

Protection Agency to support modification of the Texas A&M University System,

College Station, TX. 134 pp.
BIBLIOGRAPHY

MRID CITATION

______________________________________________________

53

-------- USDA/APHIS, 1986. Unpublished Report entitled: Residues of sodium

fluoroacetate (1080) in coyotes and on the necks of sheep due to the use of large

(60 ml) compound 1080 livestock protection collars. Denver Wildlife Research

Center, Denver, Colorado. A data report to support the registration of the 60 ml

collar. Laboratory and Pen Studies. September 1985-January 1986. 10 pp.

-------- USDA/APHIS, 1991. Correspondence from P. Joseph, summarizing the

information on the use of the Compound 1080 Livestock Protection Collar during

FY-1988, 1989, and 1990 in five western states.

-------- USFWS, 1984. Formal Section 7 Biological Opinion regarding 1 year extension

of experimental use permit for the 1080 toxic collar in Idaho, Montana and Texas.

(6704-EUP-14). (FWS/OES EPA-84-3) 5 pp.

-------- USFWS, 1985. Formal Section 7 Biological Opinion on the 1080 livestock

protection collar. Region 6 (6-RO-85-001) 18 pp.

-------- USFWS, 1986. Letter from Allan J. Mueller, Acting Field Supervisor Division of

Ecological Services, Houston, Texas to Roger Mulder, Regulatory Division, Texas

Department of Agriculture, regarding endangered species use restrictions for

Texas.

-------- Ward, J. C. and D.A. Spencer. 1947. Notes on the pharmacology ofsodium

fluoroacetate-compound 1080. Journal of the American Pharmaceutical

Association. 36(2): 59-62.

-------- Wolfe, G. 1988. Subchronic Toxicity Study in Rats with Sodium Fluoroacetate.

Study No. HLA-2399-118. Unpublished study conducted by Hazleton.

00061746 Atzert, S.P. (1971) A Review of Sodium monofluoroacetate (Compound 1080):

Its Properties, Toxicology, and Use in Predator and Rodent Control. By U.S. Fish

and Wildlife Service, Div. of Wildlife Services. Washington, D.C.: U.S. FWS.

(Special scientific report--wildlife no. 146; available from: Superintendent of

Documents, U.S. Government Printing Office, Washington, D.C. 20402;

published study; CDL:229637-B)

00061750 David, W.A.L.; Gardiner, B.O.C. (1966) Persistence of Fluoroacetate and

fluoroacetamide in soil. Nature 209(5030):1367-1368. (Also in unpublished

submission received Apr 21, 1977 under 35978-2; submitted by Wyoming, Dept.

of Agriculture, cheyenne, Wyo.; CDL: 229637-F)

00065627 Connolly, G., comp. (1980) Use of Compound 1080 in Livestock Neck Collars to

Kill Depredating Coyotes. (U.S. Fish and Wildlife Service, Denver Wildlife

Research Center; unpublished study including published data; CDL:243665-A)
BIBLIOGRAPHY

MRID CITATION

______________________________________________________

54

00144405 Burns, R.; Connolly, G.; Meeker, D.; et al. (1984) Efficacy and Hazards of

Compound 1080 in Toxic Collars: Laboratory and Pen Studies, April 1980 July

1984. Unpublished compilation prepared by US Fish and Wildlife Service,

Denver Wildlife Research Center. 53 p.

00243665 USDI Fish and Wildlife. 1980. Acute Oral Toxicity Study with Coyotes.

40016958 Goldman, P.; Milne, G. (1966) Carbon-fluorine bond cleavage. II. Studies on the

mechanism of the defluorination of fluoroacetate. Journal of Biological Chemistry

241(23):5557-5559.

40016959 Harrison, B.; Bransford, A.; MaNamara, B. (1951) Deterioration of sodium

monofluoroacetate in water and saline solutions. Federation Proceed. Pharm. and

Experimental Therapeutics 10:306-307.

40016963 Kelly, M. (1965) Isolation of bacteria able to metabolize fluoroacetate or

fluoroacetamide. Nature 208(5012):809-810.

40016964 Lien, B.; Cole, A.; Walker, J. (1979) Effect of sodium fluoroacetate ("compound

1080") on the soil microflora. Soil Biol. Biochem. 11:13-18.

40016965 Tonomura, K.; Futai, F.; Tanabe, O., et al. (1965) Defluorination of

monofluoroacetate by bacteria. Part I. Isolation of bacteria and their activity of

defluorination. Agr. Biol. Chem. 29(2): 124-128.

40016966 Walker, J.; Lien, B. (1981) Metabolism of fluoroacetate by a soil Pseudomonas

sp. and Fusarium solani. Soil. Biol. Biochem. 13: 231-235.

40016967 Corr, P.; Martire, P. (1971) Leaching by rain of sodium fluoroacetate ("1080")

from baits used for rabbit control. Austral. J. Exp. Agric. and Animal Husb.

11(Jun):287-281.

40016969 Peters, J. (1974) Environmental Contamination, Toxicology, and Residues of

Compound 1080 (Sodium Fluoroacetate) in Relation to Aerial Control Programmes

in Protection Forests: A Synopsis. Unpublished study prepared by New Zealand

Forest Service. 6 p.

40016970 Staples, E. (1968) The reduction of the sodium monofluoroacetate ("1080")

content of carrot baits of various thickness by weathering. N.Z. Jour. Agric. Res.

11(2):319-329.

40016971 Dieke, S.; Richter, C. (1946) Comparative assays of rodenticides on wild norway

rats: I. Toxicity. Reprint No. 2708, Public Health Reports 61(19):672-679.

40016990 Sullivan, J.; Smith, F.; Garman, R. (1979) Effects of fluoroacetate on the testis

of the rat. Reprod. Fert. 56:201-207.
BIBLIOGRAPHY

MRID CITATION

______________________________________________________

55

40402603 Cerven, D. (1987) Primary Eye Irritation/Corrosion in Albino Rabbits: Sodium

Monofluoroacetate Compound 1080-1% (...) Poison: Lab. Proj. ID MB 87-8886

D. Unpublished study prepared by MB Research Laboratories, Inc. 11 p.

40402604 Cerven, D. (1987) Primary Dermal Irritation in Albino Rabbits: Sodium

Monofluoroacetate Compound 1080-1% (...) Poison: Lab. Proj. ID MB 87-8886

C. Unpublished study prepared by MB Research Laboratories, Inc. 10 p.

41514901 Savarie, P.; Burns, R.; Zemlicka, D. (1990) Sodium Fluoroacetate (Compound

1080) Contamination on the Necks of Lambs with Livestock Protection Collars

(LPCs) that are killed by Coyotes: Lab Project Number: QA-65. Unpublished

study prepared by USDA-APHIS-S&T, Denver Wildlife Research Center. 227 p.

42961601 Collins, M. (1993) Sodium Fluoroacetate-Acute Toxicity to Bluegill Sunfish

(Lepomis macrochirus) Under Static Renewal Conditions: Lab Project Number:

13014.0293.6100.100: DWRC QA-294: 93-7-4847. Unpublished study prepared

by Springborn Labs, Inc. 65 p.

42961602 Collins, M. (1993) Sodium Fluoroacetate-Acute Toxicity to Rainbow Trout

(Oncorhynchus mykiss) Under Static Conditions: Lab Project Number:

13014.0293.6101.103: QA-295: 93-8-4885. Unpublished study prepared by

Springborn Labs, Inc. 68 p.

42961603 Collins, M. (1993) Sodium Fluoroacetate-Acute Toxicity to Daphnids (Daphnia

magna) Under Static Conditions: Lab Project Number: 13014.0293.6102.110:

DWRC QA-296: 93-7-4844. Unpublished study prepared by Springborn Labs, Inc.

70 p.

43210601 Campbell, S.; Beavers, J.; Grimes, J. (1994) Sodium Fluoroacetate: A Dietary

LC50 Study with the Northern Bobwhite: Lab Project Number: 247-101B:

QA-297: 94-021. Unpublished study prepared by Wildlife International Ltd. 27

p.

43210602 Campbell, S.; Beavers, J.; Grimes, J. (1994) Sodium Fluoroacetate: A Dietary

LC50 Study with the Mallard: Lab Project Number: 247-102B: 94-021: QA-298.

Unpublished study prepared by Wildlife International Ltd. 26 p.
56

APPENDIX D. Product Specific Data Call-In

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF 

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

DATA CALL-IN NOTICE

CERTIFIED MAIL

Dear Sir or Madam:

This Notice requires you and other registrants of pesticide products containing the active

ingredient identified in Attachment 1 of this Notice, the Data Call-In Chemical Status Sheet, to

submit certain product specific data as noted herein to the U.S. Environmental Protection

Agency (EPA, the Agency). These data are necessary to maintain the continued registration

of your product(s) containing this active ingredient. Within 90 days after you receive this

Notice you must respond as set forth in Section III below. Your response must state: 

1. How you will comply with the requirements set forth in this Notice and its

Attachments A through G; or

2. Why you believe you are exempt from the requirements listed in this Notice and

in Attachment 3, Requirements Status and Registrant's Response Form, (see

section III-B); or

3. Why you believe EPA should not require your submission of product specific

data in the manner specified by this Notice (see section III-D).

If you do not respond to this Notice, or if you do not satisfy EPA that you will comply

with its requirements or should be exempt or excused from doing so, then the registration of

your product(s) subject to this Notice will be subject to suspension. We have provided a list

of all of your products subject to this Notice in Attachment 2, Data Call-In Response Form, as

well as a list of all registrants who were sent this Notice (Attachment 6).

The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide

and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B). Collection of this

information is authorized under the Paperwork Reduction Act by OMB Approval No. 2070-

0107 (expiration date 12-31-92).

This Notice is divided into six sections and seven Attachments. The Notice itself

contains information and instructions applicable to all Data Call-In Notices. The Attachments

contain specific chemical information and instructions. The six sections of the Notice are:

Section I - Why You Are Receiving This Notice

Section II - Data Required By This Notice
57

Section III - Compliance With Requirements Of This Notice

Section IV - Consequences Of Failure To Comply With This Notice

Section V - Registrants' Obligation To Report Possible Unreasonable

Adverse Effects

Section VI - Inquiries And Responses To This Notice

The Attachments to this Notice are:

1 - Data Call-In Chemical Status Sheet

2 - Product-Specific Data Call-In Response Form 

3 - Requirements Status and Registrant's Response Form

4 - EPA Batching of End-Use Products for Meeting Acute Toxicology Data

Requirements for Reregistration

5 - List of Registrants Receiving This Notice

6 - Cost Share and Data Compensation Forms, and Product Specific Data Report

Form

SECTION I. WHY YOU ARE RECEIVING THIS NOTICE

The Agency has reviewed existing data for this active ingredient and reevaluated the

data needed to support continued registration of the subject active ingredient. The Agency has

concluded that the only additional data necessary are product specific data. No additional

generic data requirements are being imposed. You have been sent this Notice because you

have product(s) containing the subject active ingredient.

SECTION II. DATA REQUIRED BY THIS NOTICE

II-A. DATA REQUIRED

The product specific data required by this Notice are specified in Attachment 3,

Requirements Status and Registrant's Response Form. Depending on the results of the studies

required in this Notice, additional testing may be required.

II-B. SCHEDULE FOR SUBMISSION OF DATA

 You are required to submit the data or otherwise satisfy the data requirements specified in

Attachment 3, Requirements Status and Registrant's Response Form, within the time frames

provided. 

II-C. TESTING PROTOCOL

 All studies required under this Notice must be conducted in accordance with test standards

outlined in the Pesticide Assessment Guidelines for those studies for which guidelines have

been established. 

These EPA Guidelines are available from the National Technical Information Service

(NTIS), Attn: Order Desk, 5285 Port Royal Road, Springfield, Va 22161 (tel: 703-487-4650). 

Protocols approved by the Organization for Economic Cooperation and Development

(OECD) are also acceptable if the OECD-recommended test standards conform to those

specified in the Pesticide Data Requirements regulation (40 CFR § 158.70). When using the

OECD protocols, they should be modified as appropriate so that the data generated by the

study will satisfy the requirements of 40 CFR § 158. Normally, the Agency will not extend
58

deadlines for complying with data requirements when the studies were not conducted in

accordance with acceptable standards. The OECD protocols are available from OECD, 1750

Pennsylvania Avenue N.W., Washington, D.C. 20006.

All new studies and proposed protocols submitted in response to this Data Call-In

Notice must be in accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)].

II-D. REGISTRANTS RECEIVING PREVIOUS SECTION 3(c)(2)(B) NOTICES ISSUED

BY THE AGENCY

 Unless otherwise noted herein, this Data Call-In does not in any way supersede or change

the requirements of any previous Data Call-In(s), or any other agreements entered into with

the Agency pertaining to such prior Notice. Registrants must comply with the requirements of

all Notices to avoid issuance of a Notice of Intent to Suspend their affected products. 

SECTION III. COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

III-A. SCHEDULE FOR RESPONDING TO THE AGENCY

 The appropriate responses initially required by this Notice for product specific data

must be submitted to the Agency within 90 days after your receipt of this Notice. Failure to

adequately respond to this Notice within 90 days of your receipt will be a basis for issuing a

Notice of Intent to Suspend (NOIS) affecting your products. This and other bases for issuance

of NOIS due to failure to comply with this Notice are presented in Section IV-A and IV-B.

III-B. OPTIONS FOR RESPONDING TO THE AGENCY

The options for responding to this Notice for product specific data are: (a) voluntary

cancellation, (b) agree to satisfy the product specific data requirements imposed by this notice

or (c) request a data waiver(s).

A discussion of how to respond if you chose the Voluntary Cancellation option is

presented below. A discussion of the various options available for satisfying the product

specific data requirements of this Notice is contained in Section III-C. A discussion of options

relating to requests for data waivers is contained in Section III-D. 

There are two forms that accompany this Notice of which, depending upon your

response, one or both must be used in your response to the Agency. These forms are the

Data-Call-In Response Form, and the Requirements Status and Registrant's Response Form,

Attachment 2 and Attachment 3. The Data Call-In Response Form must be submitted as part

of every response to this Notice. In addition, one copy of the Requirements Status and

Registrant's Response Form must be submitted for each product listed on the Data Call-In

Response Form unless the voluntary cancellation option is selected or unless the product is

identical to another (refer to the instructions for completing the Data Call-In Response Form

in Attachment 2). Please note that the company's authorized representative is required to sign

the first page of the Data Call-In Response Form and Requirements Status and Registrant's

Response Form (if this form is required) and initial any subsequent pages. The forms contain

separate detailed instructions on the response options. Do not alter the printed material. If

you have questions or need assistance in preparing your response, call or write the contact

person(s) identified in Attachment 1.

1. Voluntary Cancellation - You may avoid the requirements of this Notice by

requesting voluntary cancellation of your product(s) containing the active ingredient that is the

subject of this Notice. If you wish to voluntarily cancel your product, you must submit a
59

completed Data Call-In Response Form, indicating your election of this option. Voluntary

cancellation is item number 5 on the Data Call-In Response Form. If you choose this option,

this is the only form that you are required to complete.

If you chose to voluntarily cancel your product, further sale and distribution of your

product after the effective date of cancellation must be in accordance with the Existing Stocks

provisions of this Notice which are contained in Section IV-C.

2. Satisfying the Product Specific Data Requirements of this Notice There are various

options available to satisfy the product specific data requirements of this Notice. These

options are discussed in Section III-C of this Notice and comprise options 1 through 6 on the

Requirements Status and Registrant's Response Form and item numbers 7a and 7b on the Data

Call-In Response Form. Deletion of a use(s) and the low volume/minor use option are not

valid options for fulfilling product specific data requirements.

3. Request for Product Specific Data Waivers. Waivers for product specific data are

discussed in Section III-D of this Notice and are covered by option 7 on the Requirements

Status and Registrant's Response Form. If you choose one of these options, you must submit

both forms as well as any other information/data pertaining to the option chosen to address the

data requirement.

III-C SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

If you acknowledge on the Data Call-In Response Form that you agree to satisfy the

product specific data requirements (i.e. you select item number 7a or 7b), then you must select

one of the six options on the Requirements Status and Registrant's Response Form related to

data production for each data requirement. Your option selection should be entered under

item number 9, "Registrant Response." The six options related to data production are the first

six options discussed under item 9 in the instructions for completing the Requirements Status

and Registrant's Response Form. These six options are listed immediately below with

information in parentheses to guide registrants to additional instructions provided in this

Section. The options are:

(1) I will generate and submit data within the specified time frame (Developing

Data)

(2) I have entered into an agreement with one or more registrants to develop data

jointly (Cost Sharing)

(3) I have made offers to cost-share (Offers to Cost Share)

(4) I am submitting an existing study that has not been submitted previously to the

Agency by anyone (Submitting an Existing Study)

(5) I am submitting or citing data to upgrade a study classified by EPA as partially

acceptable and upgradeable (Upgrading a Study)

(6) I am citing an existing study that EPA has classified as acceptable or an existing

study that has been submitted but not reviewed by the Agency (Citing an

Existing Study)

Option 1, Developing Data -- If you choose to develop the required data it must be in

conformance with Agency deadlines and with other Agency requirements as referenced herein

and in the attachments. All data generated and submitted must comply with the Good

Laboratory Practice (GLP) rule (40 CFR Part 160), be conducted according to the Pesticide

Assessment Guidelines (PAG), and be in conformance with the requirements of PR Notice 86-

5. 
60

The time frames in the Requirements Status and Registrant's Response Form are the

time frames that the Agency is allowing for the submission of completed study reports. The

noted deadlines run from the date of the receipt of this Notice by the registrant. If the data are

not submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to

Suspend the affected registration(s).

If you cannot submit the data/reports to the Agency in the time required by this Notice

and intend to seek additional time to meet the requirements(s), you must submit a request to

the Agency which includes: (1) a detailed description of the expected difficulty and (2) a

proposed schedule including alternative dates for meeting such requirements on a step-by-step

basis. You must explain any technical or laboratory difficulties and provide documentation

from the laboratory performing the testing. While EPA is considering your request, the

original deadline remains. The Agency will respond to your request in writing. If EPA does

not grant your request, the original deadline remains. Normally, extensions can be requested

only in cases of extraordinary testing problems beyond the expectation or control of the

registrant. Extensions will not be given in submitting the 90-day responses. Extensions will

not be considered if the request for extension is not made in a timely fashion; in no event shall

an extension request be considered if it is submitted at or after the lapse of the subject

deadline.

Option 2, Agreement to Share in Cost to Develop Data -- Registrants may only choose

this option for acute toxicity data and certain efficacy data and only if EPA has indicated in the

attached data tables that your product and at least one other product are similar for purposes of

depending on the same data. If this is the case, data may be generated for just one of the

products in the group. The registration number of the product for which data will be

submitted must be noted in the agreement to cost share by the registrant selecting this option. 

If you choose to enter into an agreement to share in the cost of producing the required data but

will not be submitting the data yourself, you must provide the name of the registrant who will

be submitting the data. You must also provide EPA with documentary evidence that an

agreement has been formed. Such evidence may be your letter offering to join in an

agreement and the other registrant's acceptance of your offer, or a written statement by the

parties that an agreement exists. The agreement to produce the data need not specify all of the

terms of the final arrangement between the parties or the mechanism to resolve the terms. 

Section 3(c)(2)(B) provides that if the parties cannot resolve the terms of the agreement they

may resolve their differences through binding arbitration.

Option 3, Offer to Share in the Cost of Data Development -- This option only applies

to acute toxicity and certain efficacy data as described in option 2 above. If you have made an

offer to pay in an attempt to enter into an agreement or amend an existing agreement to meet

the requirements of this Notice and have been unsuccessful, you may request EPA (by

selecting this option) to exercise its discretion not to suspend your registration(s), although you

do not comply with the data submission requirements of this Notice. EPA has determined that

as a general policy, absent other relevant considerations, it will not suspend the registration of

a product of a registrant who has in good faith sought and continues to seek to enter into a

joint data development/cost sharing program, but the other registrant(s) developing the data

has refused to accept your offer. To qualify for this option, you must submit documentation

to the Agency proving that you have made an offer to another registrant (who has an

obligation to submit data) to share in the burden of developing that data. You must also

submit to the Agency a completed EPA Form 8570-32, Certification of Offer to Cost Share in

the Development of Data, Attachment 7. In addition, you must demonstrate that the other

registrant to whom the offer was made has not accepted your offer to enter into a cost sharing

agreement by including a copy of your offer and proof of the other registrant's receipt of that

offer (such as a certified mail receipt). Your offer must, in addition to anything else, offer to

share in the burden of producing the data upon terms to be agreed or failing agreement to be
61

bound by binding arbitration as provided by FIFRA section 3(c)(2)(B)(iii) and must not

qualify this offer. The other registrant must also inform EPA of its election of an option to

develop and submit the data required by this Notice by submitting a Data Call-In Response

Form and a Requirements Status and Registrant's Response Form committing to develop and

submit the data required by this Notice.

In order for you to avoid suspension under this option, you may not withdraw your

offer to share in the burdens of developing the data. In addition, the other registrant must

fulfill its commitment to develop and submit the data as required by this Notice. If the other

registrant fails to develop the data or for some other reason is subject to suspension, your

registration as well as that of the other registrant will normally be subject to initiation of

suspension proceedings, unless you commit to submit, and do submit the required data in the

specified time frame. In such cases, the Agency generally will not grant a time extension for

submitting the data.

Option 4, Submitting an Existing Study -- If you choose to submit an existing study in

response to this Notice, you must determine that the study satisfies the requirements imposed

by this Notice. You may only submit a study that has not been previously submitted to the

Agency or previously cited by anyone. Existing studies are studies which predate issuance of

this Notice. Do not use this option if you are submitting data to upgrade a study. (See Option

5).

You should be aware that if the Agency determines that the study is not acceptable, the

Agency will require you to comply with this Notice, normally without an extension of the

required date of submission. The Agency may determine at any time that a study is not valid

and needs to be repeated.

To meet the requirements of the DCI Notice for submitting an existing study, all of the

following three criteria must be clearly met:

a. You must certify at the time that the existing study is submitted that the raw

data and specimens from the study are available for audit and review and you

must identify where they are available. This must be done in accordance with

the requirements of the Good Laboratory Practice (GLP) regulation, 40 CFR

Part 160. As stated in 40 CFR 160.3(j) " 'raw data' means any laboratory

worksheets, records, memoranda, notes, or exact copies thereof, that are the

result of original observations and activities of a study and are necessary for the

reconstruction and evaluation of the report of that study. In the event that exact

transcripts of raw data have been prepared (e.g., tapes which have been

transcribed verbatim, dated, and verified accurate by signature), the exact copy

or exact transcript may be substituted for the original source as raw data. 'Raw

data' may include photographs, microfilm or microfiche copies, computer

printouts, magnetic media, including dictated observations, and recorded data

from automated instruments." The term "specimens", according to 40 CFR

160.3(k), means "any material derived from a test system for examination or

analysis."

b. Health and safety studies completed after May 1984 must also contain all GLPrequired quality assurance and quality control information, pursuant to the

requirements of 40 CFR Part 160. Registrants must also certify at the time of

submitting the existing study that such GLP information is available for postMay 1984 studies by including an appropriate statement on or attached to the

study signed by an authorized official or representative of the registrant.
62

c. You must certify that each study fulfills the acceptance criteria for the Guideline

relevant to the study provided in the FIFRA Accelerated Reregistration Phase 3

Technical Guidance and that the study has been conducted according to the

Pesticide Assessment Guidelines (PAG) or meets the purpose of the PAG (both

available from NTIS). A study not conducted according to the PAG may be

submitted to the Agency for consideration if the registrant believes that the

study clearly meets the purpose of the PAG. The registrant is referred to 40

CFR 158.70 which states the Agency's policy regarding acceptable protocols. If

you wish to submit the study, you must, in addition to certifying that the

purposes of the PAG are met by the study, clearly articulate the rationale why

you believe the study meets the purpose of the PAG, including copies of any

supporting information or data. It has been the Agency's experience that

studies completed prior to January 1970 rarely satisfied the purpose of the PAG

and that necessary raw data are usually not available for such studies.

If you submit an existing study, you must certify that the study meets all requirements

of the criteria outlined above.

If you know of a study pertaining to any requirement in this Notice which does not

meet the criteria outlined above but does contain factual information regarding unreasonable

adverse effects, you must notify the Agency of such a study. If such study is in the Agency's

files, you need only cite it along with the notification. If not in the Agency's files, you must

submit a summary and copies as required by PR Notice 86-5.

Option 5, Upgrading a Study -- If a study has been classified as partially acceptable and

upgradeable, you may submit data to upgrade that study. The Agency will review the data

submitted and determine if the requirement is satisfied. If the Agency decides the requirement

is not satisfied, you may still be required to submit new data normally without any time

extension. Deficient, but upgradeable studies will normally be classified as supplemental. 

However, it is important to note that not all studies classified as supplemental are upgradeable. 

If you have questions regarding the classification of a study or whether a study may be

upgraded, call or write the contact person listed in Attachment 1. If you submit data to

upgrade an existing study you must satisfy or supply information to correct all deficiencies in

the study identified by EPA. You must provide a clearly articulated rationale of how the

deficiencies have been remedied or corrected and why the study should be rated as acceptable

to EPA. Your submission must also specify the MRID number(s) of the study which you are

attempting to upgrade and must be in conformance with PR Notice 86-5.

Do not submit additional data for the purpose of upgrading a study classified as

unacceptable and determined by the Agency as not capable of being upgraded. 

This option should also be used to cite data that has been previously submitted to

upgrade a study, but has not yet been reviewed by the Agency. You must provide the MRID

number of the data submission as well as the MRID number of the study being upgraded.

The criteria for submitting an existing study, as specified in Option 4 above, apply to

all data submissions intended to upgrade studies. Additionally your submission of data

intended to upgrade studies must be accompanied by a certification that you comply with each

of those criteria as well as a certification regarding protocol compliance with Agency

requirements.

Option 6, Citing Existing Studies -- If you choose to cite a study that has been

previously submitted to EPA, that study must have been previously classified by EPA as

acceptable or it must be a study which has not yet been reviewed by the Agency. Acceptable
63

toxicology studies generally will have been classified as "core-guideline" or "core minimum." 

For all other disciplines the classification would be "acceptable." With respect to any studies

for which you wish to select this option you must provide the MRID number of the study you

are citing and, if the study has been reviewed by the Agency, you must provide the Agency's

classification of the study.

If you are citing a study of which you are not the original data submitter, you must

submit a completed copy of EPA Form 8570-31, Certification with Respect to Data

Compensation Requirements.

Registrants who select one of the above 6 options must meet all of the requirements

described in the instructions for completing the Data Call-In Response Form and the

Requirements Status and Registrant's Response Form, as appropriate.

III-D REQUESTS FOR DATA WAIVERS

If you request a waiver for product specific data because you believe it is

inappropriate, you must attach a complete justification for the request, including technical

reasons, data and references to relevant EPA regulations, guidelines or policies. (Note: any

supplemental data must be submitted in the format required by PR Notice 86-5). This will be

the only opportunity to state the reasons or provide information in support of your request. If

the Agency approves your waiver request, you will not be required to supply the data pursuant

to section 3(c)(2)(B) of FIFRA. If the Agency denies your waiver request, you must choose

an option for meeting the data requirements of this Notice within 30 days of the receipt of the

Agency's decision. You must indicate and submit the option chosen on the Requirements

Status and Registrant's Response Form. Product specific data requirements for product

chemistry, acute toxicity and efficacy (where appropriate) are required for all products and the

Agency would grant a waiver only under extraordinary circumstances. You should also be

aware that submitting a waiver request will not automatically extend the due date for the study

in question. Waiver requests submitted without adequate supporting rationale will be denied

and the original due date will remain in force.

IV. CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

IV-A NOTICE OF INTENT TO SUSPEND

The Agency may issue a Notice of Intent to Suspend products subject to this Notice due

to failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant

to FIFRA section 3(c)(2)(B). Events which may be the basis for issuance of a Notice of Intent

to Suspend include, but are not limited to, the following:

1. Failure to respond as required by this Notice within 90 days of your receipt of

this Notice.

2. Failure to submit on the required schedule an acceptable proposed or final

protocol when such is required to be submitted to the Agency for review.

3. Failure to submit on the required schedule an adequate progress report on a

study as required by this Notice.

4. Failure to submit on the required schedule acceptable data as required by this

Notice.
64

5. Failure to take a required action or submit adequate information pertaining to

any option chosen to address the data requirements (e.g., any required action or

information pertaining to submission or citation of existing studies or offers,

arrangements, or arbitration on the sharing of costs or the formation of Task

Forces, failure to comply with the terms of an agreement or arbitration

concerning joint data development or failure to comply with any terms of a data

waiver).

6. Failure to submit supportable certifications as to the conditions of submitted

studies, as required by Section III-C of this Notice.

7. Withdrawal of an offer to share in the cost of developing required data.

8. Failure of the registrant to whom you have tendered an offer to share in the cost

of developing data and provided proof of the registrant's receipt of such offer

or failure of a registrant on whom you rely for a generic data exemption either

to:

a. inform EPA of intent to develop and submit the data required by this

Notice on a Data Call-In Response Form and a Requirements Status and

Registrant's Response Form;

b. fulfill the commitment to develop and submit the data as required by this

Notice; or

c. otherwise take appropriate steps to meet the requirements stated in this

Notice, unless you commit to submit and do submit the required data in

the specified time frame.

9. Failure to take any required or appropriate steps, not mentioned above, at any

time following the issuance of this Notice.

IV-B. BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS

UNACCEPTABLE

The Agency may determine that a study (even if submitted within the required time) is

unacceptable and constitutes a basis for issuance of a Notice of Intent to Suspend. The

grounds for suspension include, but are not limited to, failure to meet any of the following:

1. EPA requirements specified in the Data Call-In Notice or other documents

incorporated by reference (including, as applicable, EPA Pesticide Assessment

Guidelines, Data Reporting Guidelines, and GeneTox Health Effects Test Guidelines)

regarding the design, conduct, and reporting of required studies. Such requirements

include, but are not limited to, those relating to test material, test procedures, selection

of species, number of animals, sex and distribution of animals, dose and effect levels to

be tested or attained, duration of test, and, as applicable, Good Laboratory Practices.

2. EPA requirements regarding the submission of protocols, including the

incorporation of any changes required by the Agency following review.

3. EPA requirements regarding the reporting of data, including the manner of

reporting, the completeness of results, and the adequacy of any required supporting (or

raw) data, including, but not limited to, requirements referenced or included in this

Notice or contained in PR 86-5. All studies must be submitted in the form of a final
65

report; a preliminary report will not be considered to fulfill the submission

requirement.

IV-C EXISTING STOCKS OF SUSPENDED OR CANCELLED PRODUCTS

EPA has statutory authority to permit continued sale, distribution and use of existing

stocks of a pesticide product which has been suspended or cancelled if doing so would be

consistent with the purposes of the Act. 

The Agency has determined that such disposition by registrants of existing stocks for a

suspended registration when a section 3(c)(2)(B) data request is outstanding would generally

not be consistent with the Act's purposes. Accordingly, the Agency anticipates granting

registrants permission to sell, distribute, or use existing stocks of suspended product(s) only in

exceptional circumstances. If you believe such disposition of existing stocks of your

product(s) which may be suspended for failure to comply with this Notice should be permitted,

you have the burden of clearly demonstrating to EPA that granting such permission would be

consistent with the Act. You must also explain why an "existing stocks" provision is

necessary, including a statement of the quantity of existing stocks and your estimate of the

time required for their sale, distribution, and use. Unless you meet this burden the Agency

will not consider any request pertaining to the continued sale, distribution, or use of your

existing stocks after suspension.

If you request a voluntary cancellation of your product(s) as a response to this Notice

and your product is in full compliance with all Agency requirements, you will have, under

most circumstances, one year from the date your 90 day response to this Notice is due, to sell,

distribute, or use existing stocks. Normally, the Agency will allow persons other than the

registrant such as independent distributors, retailers and end users to sell, distribute or use

such existing stocks until the stocks are exhausted. Any sale, distribution or use of stocks of

voluntarily cancelled products containing an active ingredient for which the Agency has

particular risk concerns will be determined on case-by-case basis.

Requests for voluntary cancellation received after the 90 day response period required

by this Notice will not result in the Agency granting any additional time to sell, distribute, or

use existing stocks beyond a year from the date the 90 day response was due unless you

demonstrate to the Agency that you are in full compliance with all Agency requirements,

including the requirements of this Notice. For example, if you decide to voluntarily cancel

your registration six months before a 3 year study is scheduled to be submitted, all progress

reports and other information necessary to establish that you have been conducting the study in

an acceptable and good faith manner must have been submitted to the Agency, before EPA

will consider granting an existing stocks provision.

SECTION V. REGISTRANTS' OBLIGATION TO REPORT POSSIBLE UNREASONABLE

ADVERSE EFFECTS

Registrants are reminded that FIFRA section 6(a)(2) states that if at any time after a

pesticide is registered a registrant has additional factual information regarding unreasonable

adverse effects on the environment by the pesticide, the registrant shall submit the information

to the Agency. Registrants must notify the Agency of any factual information they have, from

whatever source, including but not limited to interim or preliminary results of studies,

regarding unreasonable adverse effects on man or the environment. This requirement

continues as long as the products are registered by the Agency.

SECTION VI. INQUIRIES AND RESPONSES TO THIS NOTICE
66

If you have any questions regarding the requirements and procedures established by

this Notice, call the contact person(s) listed in Attachment 1, the Data Call-In Chemical Status

Sheet.

All responses to this Notice (other than voluntary cancellation requests and generic data

exemption claims) must include a completed Data Call-In Response Form and a completed

Requirements Status and Registrant's Response Form (Attachment 2 and Attachment 3 for

product specific data) and any other documents required by this Notice, and should be

submitted to the contact person(s) identified in Attachment 1. If the voluntary cancellation or

generic data exemption option is chosen, only the Data Call-In Response Form need be

submitted.

The Office of Compliance Monitoring (OCM) of the Office of Pesticides and Toxic

Substances (OPTS), EPA, will be monitoring the data being generated in response to this

Notice.

 

Sincerely yours,

Lois Rossi, Division Director

Special Review and

 Reregistration Division

Attachments

1 - Data Call-In Chemical Status Sheet

2 - Product-Specific Data Call-In Response Form 

3 - Requirements Status and Registrant's Response Form

4 - EPA Batching of End-Use Products for Meeting Acute Toxicology Data

Requirements for Reregistration

5 - List of Registrants Receiving This Notice

6 - Cost Share and Data Compensation Forms, and Product Specific Data Report

Form
67

Attachment 1. Chemical Status Sheets

SODIUM FLUOROACETATE DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

You have been sent this Generic Data Call-In Notice because you have product(s)

containing sodium fluoroacetate.

This Generic Data Call-In Chemical Status Sheet, contains an overview of data required

by this notice, and point of contact for inquiries pertaining to the reregistration of SODIUM

FLUOROACETATE. This attachment is to be used in conjunction with (1) the Generic Data

Call-In Notice, (2) the Generic Data Call-In Response Form (Attachment 2), (3) the Requirements

Status and Registrant's Form (Attachment 2), (4) a list of registrants receiving this DCI

(Attachment 4), (5) the EPA Acceptance Criteria (Attachment 5), and (6) the Cost Share and Data

Compensation Forms in replying to this sodium fluoroacetate Generic Data Call In (Attachment

F). Instructions and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

The additional data requirements needed to complete the generic database for sodium

fluoroacetate are contained in the Requirements Status and Registrant's Response, Attachment C.

The Agency has concluded that additional product chemistry data on sodium fluoroacetate are

needed. These data are needed to fully complete the reregistration of all eligible sodium

fluoroacetate products.

INQUIRIES AND RESPONSES TO THIS NOTICE

If you have any questions regarding the generic data requirements and procedures

established by this Notice, please contact Leonard Ryan at (703) 308-8067.

All responses to this Notice for the generic data requirements should be submitted to:

Leonard Ryan, Chemical Review Manager 

Accelerated Reregistration Branch

Special Review and Registration Division (H7508W)

Office of Pesticide Programs

U.S. Environmental Protection Agency

Washington, D.C. 20460

RE: SODIUM FLUOROACETATE
68

Attachment 2. Product Specific Data Call-In Response Forms (Form A inserts) Plus

Instructions

INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM FOR 

PRODUCT SPECIFIC DATA

Item 1-4. Already completed by EPA. 

Item 5. If you wish to voluntarily cancel your product, answer "yes." If you choose this

option, you will not have to provide the data required by the Data Call-In Notice

and you will not have to complete any other forms. Further sale and distribution

of your product after the effective date of cancellation must be in accordance with

the Existing Stocks provision of the Data Call-In Notice (Section IV-C).

Item 6. Not applicable since this form calls in product specific data only. However, if

your product is identical to another product and you qualify for a data exemption,

you must respond with "yes" to Item 7a (MUP) or 7B (EUP) on this form, provide

the EPA registration numbers of your source(s); you would not complete the

"Requirements Status and Registrant's Response" form. Examples of such

products include repackaged products and Special Local Needs (Section 24c)

products which are identical to federally registered products.

Item 7a. For each manufacturing use product (MUP) for which you wish to maintain

registration, you must agree to satisfy the data requirements by responding "yes."

Item 7b. For each end use product (EUP) for which you wish to maintain registration, you

must agree to satisfy the data requirements by responding "yes." If you are

requesting a data waiver, answer "yes" here; in addition, on the "Requirements

Status and Registrant's Response" form under Item 9, you must respond with

Option 7 (Waiver Request) for each study for which you are requesting a waiver.

See Item 6 with regard to identical products and data exemptions.

Items 8-11. Self-explanatory.

NOTE: You may provide additional information that does not fit on this form in a signed

letter that accompanies this form. For example, you may wish to report that your

product has already been transferred to another company or that you have already

voluntarily canceled this product. For these cases, please supply all relevant

details so that EPA can ensure that its records are correct.
69

INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND

 REGISTRANT'S RESPONSE FORM FOR PRODUCT SPECIFIC DATA

Item 1-3 Completed by EPA. Note the unique identifier number assigned by EPA in Item

3. This number must be used in the transmittal document for any data

submissions in response to this Data Call-In Notice.

Item 4. The guideline reference numbers of studies required to support the product's

continued registration are identified. These guidelines, in addition to the

requirements specified in the Notice, govern the conduct of the required studies.

Note that series 61 and 62 in product chemistry are now listed under 40 CFR

158.155 through 158.180, Subpart C.

Item 5. The study title associated with the guideline reference number is identified. 

Item 6. The use pattern(s) of the pesticide associated with the product specific requirements

is (are) identified. For most product specific data requirements, all use patterns

are covered by the data requirements. In the case of efficacy data, the required

studies only pertain to products which have the use sites and/or pests indicated.

Item 7. The substance to be tested is identified by EPA. For product specific data, the

product as formulated for sale and distribution is the test substance, except in rare

cases.

Item 8. The due date for submission of each study is identified. It is normally based on

8 months after issuance of the Reregistration Eligibility Document unless EPA

determines that a longer time period is necessary.

Item 9. Enter only one of the following response codes for each data requirement to

show how you intend to comply with the data requirements listed in this table.

Fuller descriptions of each option are contained in the Data Call-In Notice.

1. I will generate and submit data by the specified due date (Developing Data). By

indicating that I have chosen this option, I certify that I will comply with all the

requirements pertaining to the conditions for submittal of this study as outlined in

the Data Call-In Notice. By the specified due date, I will also submit: (1) a

completed "Certification With Respect To Data Compensation Requirements"

form (EPA Form 8570-29) and (2) two completed and signed copies of the

Confidential Statement of Formula (EPA Form 8570-4).

2. I have entered into an agreement with one or more registrants to develop data

jointly (Cost Sharing). I am submitting a copy of this agreement. I understand

that this option is available only for acute toxicity or certain efficacy data and only

if EPA indicates in an attachment to this Notice that my product is similar enough

to another product to qualify for this option. I certify that another party in the

agreement is committing to submit or provide the required data; if the required

study is not submitted on time, my product may be subject to suspension. By the

specified due date, I will also submit: (1) a completed "Certification With

Respect To Data Compensation Requirements" form (EPA Form 8570-29) and

(2) two completed and signed copies of the Confidential Statement of Formula

(EPA Form 8570-4).

3. I have made offers to share in the cost to develop data (Offers to Cost Share).

I understand that this option is available only for acute toxicity or certain efficacy
70

data and only if EPA indicates in an attachment to this Data Call-In Notice that my

product is similar enough to another product to qualify for this option. I am

submitting evidence that I have made an offer to another registrant (who has an

obligation to submit data) to share in the cost of that data. I am also submitting a

completed "Certification of Offer to Cost Share in the Development Data"

form. I am including a copy of my offer and proof of the other registrant's receipt

of that offer. I am identifying the party which is committing to submit or provide

the required data; if the required study is not submitted on time, my product may

be subject to suspension. I understand that other terms under Option 3 in the Data

Call-In Notice (Section III-C.1.) apply as well. By the specified due date, I will

also submit: (1) a completed "Certification With Respect To Data Compensation

Requirements" form (EPA Form 8570-29) and (2) two completed and signed

copies of the Confidential Statement of Formula (EPA Form 8570-4).

4. By the specified due date, I will submit an existing study that has not been

submitted previously to the Agency by anyone (Submitting an Existing Study).

I certify that this study will meet all the requirements for submittal of existing data

outlined in Option 4 in the Data Call-In Notice (Section III-C.1.) and will meet the

attached acceptance criteria (for acute toxicity and product chemistry data). I will

attach the needed supporting information along with this response. I also certify

that I have determined that this study will fill the data requirement for which I have

indicated this choice. By the specified due date, I will also submit a completed

"Certification With Respect To Data Compensation Requirements" form (EPA

Form 8570-29) to show what data compensation option I have chosen. By the

specified due date, I will also submit: (1) a completed "Certification With

Respect To Data Compensation Requirements" form (EPA Form 8570-29) and

(2) two completed and signed copies of the Confidential Statement of Formula

(EPA Form 8570-4).

5. By the specified due date, I will submit or cite data to upgrade a study classified

by the Agency as partially acceptable and upgradable (Upgrading a Study). I will

submit evidence of the Agency's review indicating that the study may be upgraded

and what information is required to do so. I will provide the MRID or Accession

number of the study at the due date. I understand that the conditions for this

option outlined Option 5 in the Data Call-In Notice (Section III-C.1.) apply. By

the specified due date, I will also submit: (1) a completed "Certification With

Respect To Data Compensation Requirements" form (EPA Form 8570-29) and

(2) two completed and signed copies of the Confidential Statement of Formula

(EPA Form 8570-4).

6. By the specified due date, I will cite an existing study that the Agency has

classified as acceptable or an existing study that has been submitted but not

reviewed by the Agency (Citing an Existing Study). If I am citing another

registrant's study, I understand that this option is available only for acute toxicity

or certain efficacy data and only if the cited study was conducted on my product,

an identical product or a product which EPA has "grouped" with one or more

other products for purposes of depending on the same data. I may also choose this

option if I am citing my own data. In either case, I will provide the MRID or

Accession number(s) for the cited data on a "Product Specific Data Report" form

or in a similar format. By the specified due date, I will also submit: (1) a

completed "Certification With Respect To Data Compensation Requirements"

form (EPA Form 8570-29) and (2) two completed and signed copies of the

Confidential Statement of Formula (EPA Form 8570-4).
71

7. I request a waiver for this study because it is inappropriate for my product

(Waiver Request). I am attaching a complete justification for this request,

including technical reasons, data and references to relevant EPA regulations,

guidelines or policies. [Note: any supplemental data must be submitted in the

format required by P.R. Notice 86-5]. I understand that this is my only

opportunity to state the reasons or provide information in support of my request.

If the Agency approves my waiver request, I will not be required to supply the

data pursuant to Section 3(c)(2)(B) of FIFRA. If the Agency denies my waiver

request, I must choose a method of meeting the data requirements of this Notice

by the due date stated by this Notice. In this case, I must, within 30 days of my

receipt of the Agency's written decision, submit a revised "Requirements Status

and Registrant's Response" Form indicating the option chosen. I also understand

that the deadline for submission of data as specified by the original data call-in

notice will not change. By the specified due date, I will also submit: (1) a

completed "Certification With Respect To Data Compensation Requirements"

form (EPA Form 8570-29) and (2) two completed and signed copies of the

Confidential Statement of Formula (EPA Form 8570-4).

Items 10-13. Self-explanatory.

NOTE: You may provide additional information that does not fit on this form in a signed

letter that accompanies this form. For example, you may wish to report that your

product has already been transferred to another company or that you have already

voluntarily canceled this product. For these cases, please supply all relevant

details so that EPA can ensure that its records are correct.
72

Attachment 3. Product Specific Requirement Status and Registrant's Response Forms

(Form B inserts) and Instructions

INSTRUCTIONS FOR COMPLETING THE "REQUIREMENTS STATUS AND

REGISTRANT'S RESPONSE" FORM FOR PRODUCT SPECIFIC DATA

Item 1-3. Completed by EPA. Note the unique identifier number assigned by EPA in item

3. This number must be used in the transmittal document for any data submissions

in response to this Data Call-In Notice.

Item 4. The guidelines reference numbers of studies required to support the product's

continued registration are identified. These guidelines, in addition to the

requirements specified in the Notice, govern the conduct of the required studies.

Note that series 61 and 62 in product chemistry are now listed under 40 CFR

158.155 through 158.180, Subpart c.

Item 5. The study title associated with the guideline reference number is identified.

Item 6. The use patters (s) of the pesticide associated with the product specific

requirements is (are) identified. For most product specific data requirements, all

use patterns are covered by the data requirements. In the case of efficacy data, the

required studies only pertain to products which have the use sites and/ or pests

indicated.

Item 7. The substance to be tested is identified by EPA. For product specific data, the

product as formulated for sale and distribution is the test substance, except in rare

cases.

Item 8. The due date for submission of each study is identified. lt is normally based on 8

months after issuance of the Reregistration Eligibility Documents unless EPA

determines that a longer time period is necessary.

Item 9. Enter Only one of the following response codes for each data requirement to show

how you intend to comply with the data requirements listed in this table. Fuller

descriptions of each option are contained in the Data Call-In Notice.

1. I will generate and submit data by the specified due date (Developing Data).

By indicating that I have chosen this option, I certify that I will comply with all the

requirements pertaining to the conditions for submittal of this study as outlined in

the Data Call-In Notice.

2. I have entered into an agreement with one or more registrants to develop

data jointly (Cost Sharing). I am submitting a copy of this agreement. I

understand that this option is available on for acute toxicity or certain efficacy data

and only if EPA indicates in an attachment to this notice that my product is similar.

Enough to another product to qualify for this option. I certify that another party

in the agreement is committing to submit or provide the required data; if the

required study is not submitted on time, my product my be subject to suspension.

3. I have made offers to share in the cost to develop data (Offers to Cost

Share). I understand that this option is available only for acute toxicity or certain

efficacy data and only if EPA indicates in an attachment to this Data Call-In Notice

that my product is similar enough to another product to qualify for this option. I

am submitting evidence that I have made an offer to another registrant (who has

an obligation to submit data) to share in the cost of that data. I am also submitting
73

a completed " Certification of offer to Cost Share in the Development Data" form.

I am including a copy of my offer and proof of the other registrant's receipt of that

offer. I am identifying the party which is committing to submit or provide the

require data; if the required study is not submitted on time, my product may be

subject to suspension. I understand that other terms under Option 3 in the Data

Call-In Notice (Section III-C.1.) apply as well.

4. By the specified due date, I will submit an existing study that has not been

submitted previously to the Agency by anyone (submitting an Existing Study). I

certify that this study will meet all the requirements for submittal of existing data

outlined in option 4 in the Data Call-In Notice (Section III-C.1.) and will meet the

attached acceptance criteria (for acute toxicity and product chemistry data). I will

attach the needed supporting information along with this response. I also certify

that I have determined that this study will fill the data requirement for which I have

indicated this choice.

5. By the specified due date, I will submit or cite data to upgrade a study

classified by the Agency as partially acceptable and upgrade (upgrading a study).

I will submit evidence of the Agency's review indicating that the study may be

upgraded and what information is required to do so. I will provide the MRID or

Accession number of the study at the due date. I understand that the conditions for

this Option outlined Option 5 in the Data Call-In Notice (Section III-C.1.) apply.

6. By the specified due date, I will cite an existing study that the Agency has

classified as acceptable or an existing study that has been submitted but not

reviewed by the Agency (Citing an Existing Study). If I am citing another

registrant's study, I understand that this option is available only for acute toxicity

or certain efficacy data and only if the cited study was conducted on my product,

an identical product or a product which EPA has "grouped" with one or more

other products for purposes of depending on the same data. I may also choose this

option if I am citing my own data. In either case, I will provide the MRID or

Accession number (s) number (s) for the cited data on a "Product Specific Data

Report" form or in a similar format. If I cite another registratrant's data, I will

submit a completed "Certification With Respect To Data Compensation

Requirements" form.

7. I request a waiver for this study because it is inappropriate for my product

(Waiver Request). I am attaching a complete justification for this request,

including technical reasons, data and references to relevant EPA regulations,

guidelines or policies. [Note: any supplemental data must be submitted in the

format required by P.R. Notice 86-5]. I understand that this is my only

opportunity to state the reasons or provide information in support of my request.

If the Agency approves my waiver request, I will not be require to supply the data

pursuant to Section 3(c) (2) (B) of FIFRA. If the Agency denies my waiver

request, I must choose a method of meeting the data requirements of this Notice

by the due date stated by this Notice. In this case, I must, within 30 days of my

receipt of the Agency's written decision, submit a revised "Requirements Status

chosen. I also understand that the deadline for submission of data as specified by

the original data cal-in notice will not change.
74

Items 10-13. Self-explanatory.

NOTE:You may provide additional information that does not fit on this form in a signed

letter that accompanies this form. For example, you may wish to report that your product has

already been transferred to another company or that you have already voluntarily cancelled this

product. For these cases, please supply all relevant details so that EPA can ensure that its records

are correct.
75

Attachment 4. EPA Batching of End-Use Products for Meeting Data Requirements for

Reregistration

EPA'S BATCHING OF SODIUM FLUOROACETATE PRODUCTS FOR MEETING

ACUTE TOXICITY DATA REQUIREMENTS FOR REREGISTRATION

In an effort to reduce the time, resources and number of animals needed to fulfill the

acute toxicity data requirements for reregistration of products containing sodium fluoroacetate

as the active ingredient, the Agency has batched products which can be considered similar for

purposes of acute toxicity. Factors considered in the sorting process include each product's

active and inert ingredients (identity, percent composition and biological activity), type of

formulation (e.g., emulsifiable concentrate, aerosol, wettable powder, granular, etc.), and

labeling (e.g., signal word, use classification, precautionary labeling, etc.). Note that the

Agency is not describing batched products as "substantially similar" since some products

within a batch may not be considered chemically similar or have identical use patterns.

Using available information, batching has been accomplished by the process described

in the preceding paragraph. Notwith-standing the batching process, the Agency reserves the

right to require, at any time, acute toxicity data for an individual product should the need

arise. 

Registrants of products within a batch may choose to cooperatively generate, submit or

cite a single battery of six acute toxicological studies to represent all the products within that

batch. It is the registrants' option to participate in the process with all other registrants, only

some of the other registrants, or only their own products within a batch, or to generate all the

required acute toxicological studies for each of their own products. If a registrant chooses to

generate the data for a batch, he/she must use one of the products within the batch as the test

material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she

may do so provided that the data base is complete and valid by today's standards (see

acceptance criteria attached), the formulation tested is considered by EPA to be similar for

acute toxicity, and the formulation has not been significantly altered since submission and

acceptance of the acute toxicity data. Regardless of whether new data is generated or existing

data is referenced, registrants must clearly identify the test material by EPA Registration

Number. If more than one confidential statement of formula (CSF) exists for a product, the

registrant must indicate the formulation actually tested by identifying the corresponding CSF.

In deciding how to meet the product specific data requirements, registrants must follow

the directions given in the Data Call-In Notice and its attachments appended to the RED. The

DCI Notice contains two response forms which are to be completed and submitted to the

Agency within 90 days of receipt. The first form, "Data Call-In Response," asks whether the

registrant will meet the data requirements for each product. The second form, "Requirements

Status and Registrant's Response," lists the product specific data required for each product,

including the standard six acute toxicity tests. A registrant who wishes to participate in a

batch must decide whether he/she will provide the data or depend on someone else to do so. 

If a registrant supplies the data to support a batch of products, he/she must select one of the

following options: Developing Data (Option 1), Submitting an Existing Study (Option 4),

Upgrading an Existing Study (Option 5) or Citing an Existing Study (Option 6). If a registrant

depends on another's data, he/she must choose among: Cost Sharing (Option 2), Offers to

Cost Share (Option 3) or Citing an Existing Study (Option 6). If a registrant does not want to

participate in a batch, the choices are Options 1, 4, 5 or 6. However, a registrant should

know that choosing not to participate in a batch does not preclude other registrants in the batch

from citing his/her studies and offering to cost share (Option 3) those studies.

Seven products were found which contain sodium fluoroacetate as the active ingredient.

The products have been placed into one batch and a "no batch" category in accordance with
76

the active and inert ingredients, type of formulation and current labeling. Table 1 identifies the

products in the batch. Table 2 lists the product which has been placed in the "no batch"

category. 

 Table 1

 Batch EPA Reg. No. % Active Ingredient Formulation Type

 1 13808-7 1.0 Liquid

35975-4 1.0 Liquid

35978-8 1.0 Liquid

39508-2 1.0 Liquid

46779-1 1.0 Liquid

56228-22 1.0 Liquid

The following table lists a product that was either considered not to be similar or the

Agency lacked sufficient information for decision making and were not placed in any batch.

The registrant of this product is responsible for meeting the acute toxicity data requirements

separately.

 Table 2 (No Batch)

EPA Reg. No. % Active Ingredient Formulation Type

56228-26 90.0 Solid
77

Attachment 5. List of All Registrants Sent This Data Call-In (insert) Notice

79

Attachment 6. Cost Share, Data Compensation Forms, Confidential Statement of

Formula Form and Instructions

Instructions for Completing the Confidential Statement of Formula 

The Confidential Statement of Formula (CSF) Form 8570-4 must be used. Two legible, signed

copies of the form are required. Following are basic instructions:

a. All the blocks on the form must be filled in and answered completely. 

b. If any block is not applicable, mark it N/A. 

c. The CSF must be signed, dated and the telephone number of the responsible party

must be provided.

d. All applicable information which is on the product specific data submission must

also be reported on the CSF. 

e. All weights reported under item 7 must be in pounds per gallon for liquids and

pounds per cubic feet for solids.

f. Flashpoint must be in degrees Fahrenheit and flame extension in inches. 

g. For all active ingredients, the EPA Registration Numbers for the currently

registered source products must be reported under column 12. 

h. The Chemical Abstracts Service (CAS) Numbers for all actives and inerts and all

common names for the trade names must be reported.

i. For the active ingredients, the percent purity of the source products must be

reported under column 10 and must be exactly the same as on the source product's

label. 

j. All the weights in columns 13.a. and 13.b. must be in pounds, kilograms, or

grams. In no case will volumes be accepted. Do not mix English and metric system

units (i.e., pounds and kilograms). 

k. All the items under column 13.b. must total 100 percent. 

1. All items under columns 14.a. and 14.b. for the active ingredients must represent

pure active form. 

m. The upper and lower certified limits for ail active and inert ingredients must follow

the 40 CFR 158.175 instructions. An explanation must be provided if the proposed

limits are different than standard certified limits. 

n. When new CSFs are submitted and approved, all previously submitted CSFs

become obsolete for that specific formulation. 
80
81
82
83
84
85

United States Environmental Protection Agency 2070-0057

Washington, DC 20460 Approval Expires

CERTIFICATION WITH RESPECT TO

DATA COMPENSATION REQUIREMENTS

Form Approved

OMB No. 2070-0107,

3-31-96

Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for 

reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the

collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, 

including suggestions for reducing this burden to, Chief Information Policy Branch, PM-233, U.S. Environmental Protection 

Agency, 401 M St., S.W., Washington, DC 20460; and to the Office of Management and Budget, Paperwork Reduction Project 

(2070-0106), Washington, DC 20503.

Please fill in blanks below.

Company Name Company Number

Product Name EPA Reg. No.

I Certify that:

1. For each study cited in support of registration or reregistratiion under the Federal Insecticide, Fungicide and Rodenticide Act 

(FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the written permission of the original 

data submitter to cite that study.

2. That for each study cited in support of registration or reregistration under FIFRA that is NOT an exclusive use study, I am the 

original data submitter, or I have obtained the written permission of the original data submitter, or I have notified in writing the 

company(ies) that submitted data I have cited and have offered to: (a) Pay compensation for those data in accordance with sections 

3(c)(1)(F) and 3(c)(2)(D) of FIFRA; and (b) Commence negotiation to determine which data are subject to the compensation 

requirement of FIFRA and the amount of compensation due, if any. The companies I have notified are. (check one)

 [ ] The companies who have submitted the studies listed on the back of this form or attached sheets, or indicated on the attached

"Requirements Status and Registrants' Response Form,"

3. That I have previously complied with section 3(c)(1)(F) of FIFRA for the studies I have cited in support of registration or

reregistration under FIFRA.

Signature Date

Name and Title (Please Type or Print)

GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, with regard to the registration or

reregistration of my products, to the extent required by FIFRA section 3(c)(1)(F) and 3(c)(2)(D).

Signature Date

Name and Title (Please Type or Print)

EPA Form 8570-31 (4-96)
86

APPENDIX E. List of Available Related Documents

The following is a list of available documents related to sodium fluoroacetate. It's purpose

is to provide a path to more detailed information if it is needed. These accompanying documents

are part of the Administrative Record for Sodium fluoroacetate and are included in the EPA's

Office of Pesticide Programs Public Docket.

1. Health and Environmental Effects Science Chapters

2. Detailed Label Usage Information System (LUIS) Report

3. Sodium fluoroacetate RED Fact Sheet

4. PR Notice 86-5 (included in this appendix)

5. PR Notice 91-2 (included in this appendix) pertains to the Label Ingredient

Statement